Chris,
I don't think that is correct.
According to page 18 of the "Guide to the implementation of directives
based on the New Approach and the Global Approach"
http://europa.eu.int/comm/enterprise/newapproach/legislation/guide/index
.htm
"Placing on the market is the initial action of making a product
available for the first time on the Community market, with
a view to distribution or use in the Community. Making available
can be either for payment or free of charge."
Therefore, I believe the RoHS Directive does not affect products that
are currently being sold. This is the idea of being "Grand fathered". It
will not require redesign of everything. Only "new products". If you
have been selling/marketing Model xyz before July 2006, you can continue
to market Model xyz WITHOUT needing to comply with RoHS. A new Model
xyz2, WOULD need to comply if first introduced after July 2006.
However, for some of us that design PCBs that are currently on the
market, we may still need to redesign our product to be compliant if we
intend on finding new business for that product where a company would
use it in new designs(end-products) of which they intend to introduce
after July 2006. If we are not looking for new business for that
particular product, then it can continue to be sold in the EU for use in
a currently marketed end-product.
David
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of James, Chris
Sent: Thursday, March 31, 2005 3:04 AM
To: [log in to unmask]
Subject: Re: [LF] ROHS and existing product
RoHS applies to all freshly built product put on the market after July
2006.
It matters not if it is a new design or old design.
When the directive says "new product" it means a product, or perhaps
should I say, item (i.e a fridge, a TV, not a product line) that has
just been manufactured. And where "for the first time" means that
particular item has never been sold before.
So if you are currently selling Model xyz in the EU, then yes if you
want to carry on selling Model xyz in the EU after July 2006 then it
must be compliant with RoHS after that date. So depending how long your
manufacturing chain is you probably need to be producing compliant
product several months before July 2006.
Does that help?
Regards,
Chris
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Geoff Haines
Sent: 31 March 2005 01:52
To: [log in to unmask]
Subject: [LF] ROHS and existing product
Hello List members,
Can anyone tell me categorically whether existing product already on the
EU
market must comply with ROHS by July 2006, or whether the ROHS Directive
only applies to new product placed for the first time on the EU market?
Regards,
Geoff Haines
Jands Pty Ltd
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