RoHS states -
Article 2 item 3. This Directive does not apply to spare parts for the
repair,
or to the reuse, of electrical and electronic equipment put on
the market before 1 July 2006.
So the electronics being resold as used should be exempt from RoHS, but most
likely not exempt from reclamation under WEEE.
But, I'd:
1 - want a legal opinion
2 - would like to know if it was remanufactured outside the EU can it be
shipped back in???
Cheers?
Dick Anderson - 978-442-5165
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Kallin, Dan
Sent: Tuesday, February 22, 2005 4:33 PM
To: [log in to unmask]
Subject: Re: [LF] RoHS compliance-- recycled or remanufactured
Product
Does any one have any solid references for this? It seems like a very grey
area.
For example, if a non-compliant product is sold to a customer in May 2006.
Returned to the manufacturer, "re-manufacturered" consisting of cleaning and
testing, no new components, and offered back into the marketplace as a
remanufactured product after July 2006, It seems like it should not be
covered by RoHS as it has already been placed on the market. It certainly
seems key to the concern about keeping this stuff out of landfills to
encourage this type of activity.
Is there precedence for this from other directives?
Is a paper trail sufficient to document the previous sale?
Lets keep it simple and assume the initial sale was in the EU and it will be
marked in compliance with WEEE and keep pre-august 2005 products separate.
I thought there was previous discussion on this but could not find it in the
archives.
Dan
__________________________________________
Dan Kallin Environmental & Safety Engineer
Bose Corporation Framingham, MA 01701
[log in to unmask]
508-766-7136 (phone)
508-766-7086 (fax)
__________________________________________
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Denis Ryskamp
Sent: Tuesday, February 22, 2005 2:24 PM
To: [log in to unmask]
Subject: Re: [LF] RoHS compliance-- recycled Product
We refurbish some of our printers and other equipment then resell. Where or
whom might I contact to verify refurbished products would be exempt?
I understand that we have a catch 22 regarding recycling non compliant parts
into new products. We are requested to recycle but the product would not be
compliant.
Denis
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of James, Chris
Sent: Tuesday, February 22, 2005 12:25 PM
To: [log in to unmask]
Subject: Re: [LF] RoHS compliance-- recycled Product
If you use co
If you just repair and resell then that is fine.
If you use components from the junker to build what is ostensibly a new
product and sell that, then that is a different matter and is a
situation currently up for an exemption.
Regards,
Chris
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Denis Ryskamp
Sent: 22 February 2005 17:10
To: [log in to unmask]
Subject: [LF] RoHS compliance-- recycled Product
question
If one recycles or refurbishes an item and resells that item, does this
need
to be RoHS compliant?
Denis Ryskamp
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