Hi Denis, Chris, Dan, IPC LF Listservers,

Denis I hope you read Dan's link and saw EdB's addition.

From a reading, it is easier for an importer that is detached from any
obligations to comply with this guidance document than it seems to be for
an EU source. Although, even with detached importers, just like the day of
annual inventory product flow, markings' must be controlled before the
August date. By detached I mean they don't manage or control any internal
to the EU distribution points and are not an EU recognized brand.

Everything will depend on how your company operates and how your product
ends up being received by the end user. Mail order is a big bug a boo, and
an untouched area, yet to keep themselves clean they should comply as well.

Let us say that you own an EU distributor and you stock them. If after this
day of August they have 1000 parts on their shelves without a put in
service mark of after this August date then the "electronic/electrical
grocery" clerks have to put on labels. Now if the distributor becomes the
producer then they might put some shared burden on you.

By the Way, unless someone corrects me, as we near these dates and see the
process of how to comply IT SEEMS like the EU writers didn't think out into
the future.


Yours in Engineering, Dave
Y i Engr, MA/NY DDave

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