Hello Jerry,
First question to always be asked is:
Is it a consumer product, or is it sold in a business to business
transaction (B2B) ?
And I always advise my customers to read the German ElektroG (Electrical
Law) since it also details the EEE parts that legally fall under RoHS and
WEEE.
The link to visit is ;
http://www.bmu.de/files/pdfs/allgemein/application/pdf/elektrog_uk.pdf
and an interesting website for all US-Based manufacturers exporting to
Europe is the Department of Commerce and the weblink;
www.buyusa.gov/europeanunion/weee.html
Kindest regards,
Arnold Offner
Phoenix Contact Inc. - USA
Industry Associations & Committees
Program Lead - RoHS & WEEE Directive
Box 4100
Harrisburg, PA 17111-0100
United States of America
Telephone: USA - 717 - 948 3469
Cellphone: USA - 717 - 215 0155
Facsimile: USA - 717 - 948 3468
E-Mail: <[log in to unmask]>
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| | "Kallin, Dan" |
| | <dan.kallin@EARTH|
| | TECH.COM> |
| | Sent by: Leadfree|
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>------------------------------------------------------------------------------------------------------------------------------|
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| To: [log in to unmask] |
| cc: |
| Subject: Re: [LF] RoHS and Prototype Equipment |
>------------------------------------------------------------------------------------------------------------------------------|
Take a good look at the definition of placed on the market in the blue book
and talk to your counsel about the risk.
http://europa.eu.int/comm/enterprise/newapproach/legislation/guide/legis
lation.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.
There is of course some grey areas:
Placing on the market is considered not to take place where a product is:
transferred from the manufacturer in a third country to an authorised
representative in the Community whom the manufacturer has engaged to ensure
that the product complies with the directive (32); a
manufacturer for further measures (for example assembling, packaging,
processing or labelling) (33);
circulation by customs, or has been placed under another customs procedure
(for example transit, warehousing or temporary importation), or is in a
free zone (34);orting it
to a third country;nstrations
(35); or
representative established in the Community, where the product is not yet
made available, unless otherwise provided for in the applicable directives.
Dan Kallin
Program Director
EH&S Management, Consulting and Compliance
Earth Tech, Inc.
196 Baker Avenue
Concord, Massachusetts 01742-2167
Phone: 978.371.4155 Fax: 978.371.2468
Mobile: 978.760.0779
[log in to unmask]
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of James, Chris
Sent: Friday, September 30, 2005 9:44 AM
To: [log in to unmask]
Subject: Re: [LF] RoHS and Prototype Equipment
As long as you don't "place it on the market" it matters not. So yes you
could import it but you wouldn't be able to sell it or otherwise "place on
the market".
Regards,
Chris
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Jerome Wagner
Sent: 30 September 2005 14:09
To: [log in to unmask]
Subject: [LF] RoHS and Prototype Equipment
Folks: Please help me with an interpretation on this: Let's say a piece of
EEE hardware is being developed and prototyped and is to enter an EU
country shortly after July 1, 2006, to be tested, evaluated, and, perhaps,
enhanced, there for a period of time. The agreement is for the equipment
to:
i) be shipped out of EU on completion of testing; or
ii) may be left there for eventual sale and longterm use. Assume that
title for the equipment remains with the State-side manufacturer until time
of sale...
Would you expect such prototype hardware to be subject to RoHS at all? on
initial entry into EU country? on transfer of title/sale? Any other
relevant points?
Thanks! jw
!! God Blesses !!
Jerry Wagner Dept 0056 Environmental Engineering B096-1
x56275 pg 58888-0658 (607)755-6275 fax: (607)755-6282
Huron Real Estate Associates, LLC and Endicott Interconnect
Technologies,
Inc.
Via the Internet: [log in to unmask] [NOTES: Jerome
Wagner/Huron/EIT]
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