Eric is correct in his original assumption; an upgrade or repair to an
existing system is exempt. It does not matter whether the upgrade is
internal or external to the original box - the exemption applies to "the
system" being upgraded........... plus of course there is the network
infrastructure exemption as well, as also pointed out.
Would suggest you produce an internal formal and dated document for your
justification for exemption and put on file - you can then produce this
to the enforcer if he ever comes knocking and even if he disagrees with
your view he should be far more lenient than if you didn't have the
document.
Regards,
Chris
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Kallin, Dan
Sent: 09 June 2006 21:23
To: [log in to unmask]
Subject: Re: [LF] JBOD Storage upgrades RoHS Exempt?
It seems to me if they are considered a spare part they may be correct.
(Article 2 para 3) Though that seems a stretch to me.
IT Storage has an exemption for using leaded solder until 2010, In my
opinion, the rest of the unit would need to be RoHS compliant.
Dan Kallin
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 Eric Lunzer
Sent: Friday, June 09, 2006 1:14 PM
To: [log in to unmask]
Subject: [LF] JBOD Storage upgrades RoHS Exempt?
We are a manufacturer of storage equipment and I got a question on RoHS
legislation and whether upgrades in this particular case are exempt.
Essentially, a customer buys a system with a RAID controller and then
they can upgrade storage capacity by buying additional independent JBOD
rack systems which would plug into the controller. Because it is older
technology, we are planning on obsoleting the entire product line;
however, a customer of ours is under the understanding that they can
still sell Non-RoHS JBOD systems after July 1 because they are upgrades
to existing units already in the field thus RoHS exempt. This logic
would have less impact to the environment since it would prolong the
life of the product and customers would not have to replace entire
systems out in the field. Is our customer right in their interpretation
of upgrades being RoHS exempt in this circumstance?
Eric
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