If you have a pre-directive product (item) already once sold on the EU
market, then you may resell it second hand on the EU market post
directive without having to comply BUT if you drastically modify the
product before selling it "second hand" it may be considered as a new
product not a second hand one. If considered in this case as new then it
would have to comply.
Extreme example: take a 1960's black and white TV, if I sell it second
hand in 2007 with no mods then OK it does not need to comply. If I
upgrade it with a SMPSU and convert it to 625 lines and colour then it
would be considered a new product (let alone a miracle! :) )
Regards,
Chris
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Bache, Paul
Sent: 31 March 2005 15:20
To: [log in to unmask]
Subject: Re: [LF] ROHS and existing product
Chris, so how do you interpret paragraph 3 on page 15, section 2 "Scope
of New Approach directives"
"Products that have been subject to important changes may be considered
to be new products that have to comply with the provisions of the
applicable directives when placed on Community market and put into
service. This has to be assessed on a case-by-basis, unless otherwise
provided for" ?
Regards
Paul Bache
Component Specialist
Tandberg Television Ltd
Strategic Park
Comines Way
Hedge End
Southampton
Hampshire
SO30 4DA
United Kingdom
+44(0)23 8057 3089
+44(0)23 8057 3100
[log in to unmask]
http://www.tandbergtv.com
-----Original Message-----
From: James, Chris [mailto:[log in to unmask]]
Sent: 31 March 2005 15:02
To: [log in to unmask]
Subject: Re: [LF] ROHS and existing product
It is most certainly not Grandfathered and applies as I have stated.
This is the reason for all the consternation in having to redesign
existing products so they comply. We only wish what you say were true.
I have been working on this for over 3 years in close conjunction with
the DTi, SMART Group and others so I think I know what I am saying.
The Eurospeak in the directives may seem confusing and you might try and
read into the wording something different - it is a frequent error to
those new to reading these documents. Try reading the Blue Book for some
closer defs or look at the UK guidance. See last sentence in clause 25
of the UK RoHS guidance (in bold red if you receive in html):
24. "Put on the market" is not defined in the Regulations or in the
Directive, but it is
being interpreted in the same way as the term 'placing on the market',
which is
defined in the European Commission's "Guide to the implementation of
directives
based on the New Approach and the Global Approach" (commonly referred to
as
the "Blue Book"). This says that '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.
25. A product is placed on the Community market when it is made
available for the
first time. This is considered to take place when a product is
transferred from the
stage of manufacture with the intention of distribution or use on the
Community
market. Moreover, the concept of placing on the market refers to each
individual product,
not to a type of product, and whether it was manufactured as an
individual unit or in a series.
You may of course chose to ignore it but then you won't be able to sell
your products in the EU after July 2006.
Regards,
Chris
-----Original Message-----
From: David Thorndike [mailto:[log in to unmask]]
Sent: 31 March 2005 14:33
To: (Leadfree Electronics Assembly Forum); James, Chris
Subject: RE: [LF] ROHS and existing product
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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