So what are you doing about product you are selling in MS who already
have legislation?

Historic waste is everything pre 13 Aug 2005 - you can't have different
dates throughout the MS.

If you apply the wheelie without the bar but have the date marked on the
unit you cover all bases.

Bottom line it's your decision, your legal fees, your product market -
everyone else is doing what the letter asks, or rather I have seen no
other dissenters on several other WEEE/RoHS forums - if you go to a
compliance scheme that's what they'll say you should be doing.

Regards,
Chris
 


From: Colgan, Christopher [Harman Pro Group UK]
[mailto:[email protected]] 
Sent: 25 November 2005 17:00
To: James, Chris; Emc-Pstc (E-mail)
Subject: RE: WEEE labelling in the UK

But that's my point.  All the guidelines etc state something like "The
Government proposes to implement on 13 August 2005 the WEEE
Directive...." but they haven't.  The draft Statutory Instrument hasn't
even been completed, let alone laid before parliament.  Without an SI,
there's no legislation, ergo, there's no enforcement.

My concern is that we will mark products before legislation requires us
to do so.  This may confuse the historical waste issue if the SI
declares a date other than August 13.  I don't think you can have
retrospective legislation. ie how can you have a law that state "all
products will be marked from last year"?

The UK Government are in breach of the directive and they're in trouble
with Brussels.  In the meantime the poor manufacturers are being told to
prepare for WEEE legislation but not being told exactly what the WEEE
legislation is!

Cheers

Chris





_____________________________________________
Christopher Colgan
Compliance Engineer

Soundcraft & Studer
Harman International Industries Ltd
Tel: +44 (0) 1707 668081

Fax: +44 (0) 1707 660755

EMail: [email protected]

Web : http://www.soundcraft.com
Web : http://www.studer.ch


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-----Original Message----- 
From: James, Chris [mailto:[email protected]]
Sent: 25 November 2005 16:43
To: Colgan, Christopher [Harman Pro Group UK]; Emc-Pstc (E-mail)
Subject: RE: WEEE labelling in the UK


Chris - see topmost bullet point on page 2 of this:

http://www.dti.gov.uk/sustainability/weee/Planning_for_Implementation.pd
f

Marking still required from the 13th Aug 2005........


Regards,
Chris


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