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September 2005

Leadfree@IPC.ORG

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Subject:
From:
"Smith, Rick" <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Thu, 1 Sep 2005 13:54:25 -0500
Content-Type:
text/plain
Parts/Attachments:
text/plain (320 lines)
Its up to you, but you should report the specifics of that issue to your
federal government trade rep, in the US it would be either the Secretary
of State or the US Trade representative to the WTO. 

These are "anti-trust" type issues that affect the entire industry to
some degree, and will work out later somehow. 

What ever you decide you are still at a disadvantage over the EU based
competition because you have to guess price mark-up to your product to
cover unknown future recycling costs.

Local EU producers will guess these costs better because they have guys
on the ground who know the language and local recycle costs, so they do
not have to deal with middlemen like recuple or rene.

Later on, all of those non-EU companies that are required to pay
recycling costs may end up becoming the "golden egg woven out of straw"
for many EU companies as they find it easy to jack up prices at will.

I would talk with your lawyer and pass the recycle coststo your end user
if you qualify, that way, you can still beat the local guy on price..

Rick Smith
Senior Product/ Component Engineer
 
Phone: (512)652-3544
Fax:     (512)652-3545
Cell:     (512)299-6925
Email:   [log in to unmask]
 
ClearCube Technology, Inc
8834 Capital of Texas Hwy N
Austin, TX 78759
 
www.clearcube.com
 

-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of James Calder
Sent: Thursday, September 01, 2005 12:16 PM
To: [log in to unmask]
Subject: Re: [LF] WEEE Escrow Account???

That is true. We have run into situations where the distributor will
look to the competition which is local based and sell their products.
This way they can avoid liability since the competition is already
registered.  Many companies are going ahead and registering in EU to
avoid this situation.  Some recycling organizations allow the foreign
enterprise to take on a mandate for their distributor.

James Calder
AGEUS Solutions Inc
www.ageussolutions.com


-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of James, Chris
Sent: Thursday, September 01, 2005 12:34 PM
To: [log in to unmask]
Subject: Re: [LF] WEEE Escrow Account???

You can only amend sales agreement by mutual agreement - you can't
impose the obligation on the purchaser........

Regards,
Chris
____________


-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Smith, Rick
Sent: 01 September 2005 17:34
To: [log in to unmask]
Subject: Re: [LF] WEEE Escrow Account???

The end user brings it into the EU, then he is responsible. Period.

If your company is like ours where we have a direct sales force present
in the EU, then you need to amend sales agreements, or if you want,
arrange to pay recycling costs.



Rick Smith
Senior Product/ Component Engineer

Phone: (512)652-3544
Fax:     (512)652-3545
Cell:     (512)299-6925
Email:   [log in to unmask]

ClearCube Technology, Inc
8834 Capital of Texas Hwy N
Austin, TX 78759

www.clearcube.com


-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Scott Hoeptner
Sent: Thursday, September 01, 2005 11:23 AM
To: [log in to unmask]
Subject: Re: [LF] WEEE Escrow Account???

What about a situation where an end-user purchases direct from a source
outside of the EU?

Regards,
Scott


-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of James, Chris
Sent: Thursday, September 01, 2005 9:09 AM
To: [log in to unmask]
Subject: Re: [LF] WEEE Escrow Account???

If you don't have a legal entity within a member state then why are you
worried about WEEE? The obligation is down to your
importers/distributors..............

Regards,
Chris
____________


-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Smith, Rick
Sent: 01 September 2005 17:06
To: [log in to unmask]
Subject: Re: [LF] WEEE Escrow Account???

Have heard nothing about escrow account.

I know that some of the recycle companies that deal with foreign
companies are charging large fees up front, (even in some cases just to
talk about services) and they have monthly maintenance costs.

If your product is not sold to private households or can not be
otherwise classified as such, you can and should probably pass this
responsibility (recycling and costs) on to the end user by amended sales
agreements per 2002/96/EC Article 9.

The amendment will help your business avoid a margin hit due to unknown
future recycling costs and if you don't have the amendment, you can't
avoid those costs.

asta



Rick Smith
Senior Product/ Component Engineer

Phone: (512)652-3544
Fax:     (512)652-3545
Cell:     (512)299-6925
Email:   [log in to unmask]

ClearCube Technology, Inc
8834 Capital of Texas Hwy N
Austin, TX 78759

www.clearcube.com


-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of jeff collins
Sent: Thursday, September 01, 2005 10:48 AM
To: [log in to unmask]
Subject: [LF] WEEE Escrow Account???

Hi Group,

We are working on implementing our WEEE program. We intend on using a
qualified agent in Europe to be our representative for the collection
process. I've heard that in addition to this we must setup an Escrow
account within the EU. Any truth to that? If so how do you go about
getting the account setup? And how much money needs to be in the
account. Any info on this subject is appreciated.

Thanks in advance,

Jeff C







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