John,
The answer to your question is the holy grail of many of us in a similar
situation who manufacturer "low volume" high end professional products.
Having pursued a definitive answer since the publication of the
directives we have found no one willing to give such. "The courts will
decide" is the usual answer.
What we have been told by people best placed to know is that the
categories are purely for example and "consumer" does not necessarily
mean what it generally is interpreted as. The best answer so far is that
unless you can see your products specifically classified as exempt then
you should consider yourself in and obligated.
The other arguments are that for B2B products the cost of complying with
WEEE will be significantly less than fighting any legal action. Unless
you manufacture and market directly yourself in the EU then it will be
your importers and distributors who will be obligated under WEEE, but
again at a B2B level and where under most circumstances the obligation
can be passed on to the purchaser. (Do you belong to PALMA or any other
trade association?)
For RoHS, the reality is that components will become Pb-F/RoHS compliant
and so you will be more or less forced down the compliant route so again
it is possibly better to go with the flow now rather than face legal
action or possible import bans for non compliancy. In addition more and
more of the world will come on board with such legislation; China
intends to match the EU if not precede the EU by 6 months with very
similar legislation.
A bitter pill to swallow it is. Ill informed politicians have put us in
this position without proper answers or any forethought to the wide
reaching implications on the manufacturing community.
The Japanese have again led the way in business acumen, with a
reasonable step by step process towards reducing the impact of
electronic waste. If only Europe had looked to their
approach............ but then the politicians never learn.
Regards,
Chris
____________________________________________________
Chris James
Engineering Services Manager
Dolby Laboratories, Inc.
Direct: +44 1793 842136
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Thorup, John
Sent: 07 December 2004 01:18
To: [log in to unmask]
Subject: [LF] scope of directives
Having just read the directives from beginning to end I have a question
about the scope of the directives. Article 2 paragraph 1 of the RoHS
directive 2002/95/EC states... "this directive shall apply to electrical
and
electronic equipment falling under the categories 1, 2, 3, 4, 5, 6, 7
and 10
set out in annex 1A to directive No 2002/96/EC (WEEE) and to electric
light
bulbs, and luminaries in households."
In reading WEEE we find these products to be household appliances,
telecom,
consumer equipment, lighting, tools, toys and such.
If this is true would not an OEM of niche, high end, professional
broadcast
equipment that has absolutely no market or application in any household
be
exempt?
Thanks, John
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