Hi Roger, IPC LF Listservers,

<If the equipment changes ownership from a legal entity outside the EU to
another legal entity inside the EU (in this case, another division of the
same group of companies), then, in my view, this is "placing on the market"
"for the first time". Yes, it has to comply and the date of transfer of
ownership to the European subsidiary company defines the date of putting on
the market. This leaves aside the matter of whether the equipment is
exempt.>
<
<Best regards, Roger Bilham ) ( Falcon Metals UK)>

Roger, I disagree with you, yet do see how you might have this view.

Hopefully you saw my other note that kind of reads the same as this one.

Ownership transfer, or EU companies buying companies with SnPb technology
and using it in the EU is a bit different than buying used equipment to put
on the EU marketplace. After all nothing is making current EU companies
totally discard current SnPb technology so why should it stop the capital
process of EU companies consuming out of EU companies.

So we will wait for a test case in the EU Court with of course an EU
company being the bad guy/gal. A USA buffalo nickel is my wager that my
thought process will prevail. (I know a tiddly wager)

Yours in Engineering, Dave
YiEngr, MA/NY DDave

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