Ken:  the UK's DTI draft RoHS Regulations and Guidance self declaration
refers to the product level, and is based on the assumption that after
the July 1, 2006 effective date, all new products "placed on the market"
in the UK will be assumed to be compliant with their interpretation of
the regulations.  They will not require any specific declaration
documentation, marking or labeling- the simple fact that a producer is
importing or selling product in the UK will be taken to indicate that
they understand the requirements and have taken "due diligence" with
their manufacturing and supply chain to ensure compliance.  If
requested, producers will be expected to provide "technical
documentation" to regulators within 28 days that supports their
compliance.  Although the specific form of this documentation has not
been defined, Materials Composition Declarations from suppliers, which
clearly indicates RoHS compliance is likely to be expected.  At their
option, UK regulators may perform analytic testing to test for
compliance.

I hope this helps- if you have further questions, please let me know.  I
may not have answers, but I will try...

Regards, Richard Kubin.


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