Chris, It's 200K units in total put on the market, not per mfr. So even mfrs with small volumes in high volume product markets targeted by EuP will have to comply. Problem is, there's nothing to comply with...there are no "implementing measures" yet. That's where the rubber meets the road. Industry has to convince the EU that it can accomplish this voluntarily to avoid them, according to the directive (yet they're pressing ahead with some). Don't expect Industry to do so or be successful. Once the implementing measures are in place (next year?) expect a few years before they're in force to comply. The impact of EuP can not be understated. What we went through with RoHS, at least in terms of getting attribute data nobody had ever asked for to flow down the supply chain, will be similar with both REACH and EuP. EuP requires that energy attributes for potentially all materials (which indirectly could drive material selection) will be required. REACH requires detailed substance and application attributes to be shared up and down the supply chain (there are serious IP and confidentiality issues here). The electronics industry, IMHO, and our supply chain is poorly prepared. So this brings me to yet another advertisement: The US National Institute of Standards and Technology (NIST) is holding a workship in late September entitled "Innovation and Competitiveness: A Strategic Approach to Emerging Chemical Issues". Read more about it at http://www.cstl.nist.gov/confs/emergingchemforum/index.htm Yours Truly is presenting on what the electronics industry has gone through; you'll hear what other industries (automotive, construction, etc.) have gone through. We're not the only ones subject to the whims of the Environment DG... I would enjoy meeting some of you there since the point of this workshop is to discuss and brainstorm just how we get ahead of this, or at least how to work more closely with these governments to implement more sensible, and effective, product-focused environmental laws. Because we ain't gonna stop it from happening. As Cowboy Neal Cassidy said, "you're either on the bus or off the bus". As I have said elsewhere, REACH could have a minimal effect on the electronics industry (more PCNs and slightly lower reliability) or it could have a dramatic effect. The industry has, to my knowledge, failed to perform a comprehensive or even moderately so risk analysis and understand the potential exposure. For instance, Bisphenol A could be restricted...suddenly we have to find a new mold compound for "plastic" electronic components. That could be as subtle and significant as replacing lead-based solder. Mike Kirschner On Wed, 30 Aug 2006 17:36:25 +0100, James, Chris <[log in to unmask]> wrote: >Has >Date is 11 Aug 2007 so even less time to comply John! Has anyone had clarification on Art 15 2(a): (a) the EuP shall represent a significant volume of sales and trade, indicatively more than 200 000 units a year within the Community according to most recently available figures; Does this mean 200k units per mfr or just 200k units from all mfrs? Regards, Chris -----Original Message----- From: Leadfree [mailto:[log in to unmask]] On Behalf Of John Burke Sent: 30 August 2006 17:07 To: [log in to unmask] Subject: Re: [LF] REACH Not really, it WILL impact the raw chemicals supply industry, but will not have the impact on the electronics manufacturing sector that lead in solders had. You might want to be more concerned about the EuP laws which will have a far reaching impact and which have been passed as law already, they cut in on August 17th 2007. John -----Original Message----- From: Leadfree [mailto:[log in to unmask]] On Behalf Of Paul Jackson Sent: Wednesday, August 30, 2006 12:50 AM To: [log in to unmask] Subject: [LF] REACH Is REACH going to be like RoHS... what does it mean for the industry as a whole....? http://www.netregs.gov.uk/netregs/legislation/380525/1285481/?lang=_e Paul Jackson Hotline Purchasing Manager Black Box Network Services Tel: 0118 965 5225 Fax: 0118 9751 565 E-Mail: Paul <mailto:[log in to unmask]> [log in to unmask] Web: www.blackbox.co.uk One source for worldwide infrastructure services ************************************************************************ **** ***** One source for worldwide infrastructure services Black Box is the world's largest technical services company dedicated to designing, building and maintaining today's complicated network infrastructure systems. Black Box services clients of all sizes in 141 countries throughout the world. 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