Well put Scott.

-----Original Message-----
From: Leadfree [mailto:[log in to unmask]]On Behalf Of Douglas, Scott
Sent: Thursday, March 31, 2005 9:34 AM
To: [log in to unmask]
Subject: Re: [LF] ROHS and existing product


IPC List,

Having watched the threads on when a product must be compliant, I offer this
comment.

The easiest way to look at the problem is this: A product on a shelf at the
point of sale to the end user on 1 July 2006 must be RoHS compliant. The
seller, dealer, distributor, whatever, cannot sell that product after that
date unless it is compliant. It does not matter when the product was first
designed or manufactured. It does not matter whether the product is one of a
kind or one of thousands of copies of that design. It does not matter
whether this is the first time a particular point of sale is selling this
product or if it is sale number 1,000. Any product sold 1 July 2006 or after
must be compliant. Period.

I would add that the above is suggested to apply to brand new product, not
used or re-furbished. That is only my reading between the lines and not
anything the various documents would indicate. One could argue the
re-furbished part either way I suppose. I also realize that any product sold
to an end user prior to 1 July 2006 does not need to be RoHS compliant and
can be repaired with non-compliant parts, etc.

One can dissect the various documents and statements from the multitude of
sources in any of a dozen ways. One can then translate any of these into
something that suits ones own purpose. But in reality, the simplest approach
is as I described above and the K.I.S.S. method always works for me.

Regards,
Scott

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