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July 2006

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Subject:
Basics on when a China RoHS content table is necessary
From:
"Kealey, Doug" <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Mon, 31 Jul 2006 11:48:34 -0500
Content-Type:
text/plain
Parts/Attachments:
text/plain (41 lines) 
Dear Group,
If you manufacture a product that DOES contain substances above the
Concentration Limits (CLs), and the product is in the Catalogue,
                a.)  you have to convert it to RoHS, according to the
Catalogue's specific timeline for that category of product.  Agree?
Section 6.1 of the Marking Std. implies that
                b.)  a RoHS compliant product does NOT need the Substance
Table in the brochure.  Agree?
If a and b are true, then (for a non-RoHS product) for the period between
Mar 1, 2007 and some deadline stated in the Catalogue, your manual needs a
Substance Table.  You can remove the Substance Table when you remove the
substances from the product, backed up by China RoHS and CCC certifications.
True?

If your non-RoHS product is NOT in the Catalogue, then you must leave the
Substance Table in the manual as long as keep selling that non-RoHS product.
Agree?

Thanks for your input,
Doug Kealey
Sr. Compliance Engineer
Garmin International Inc.
http://www.garmin.com <http://www.garmin.com/>
913-440-5210
[log in to unmask]



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