The blue guide is a good starting point.
>From a practical perspective, you need to look at when does the product become property of an EU company and has passed EU customs. Many times product is in a non EU company owned distribution center/warehouse in an EU country and not available to EU customers. This product is not “on the market”. If the product has transferred to an EU company and then the regulation changes, that product is still legal to sell. Now the retailer’s and customer’s view may be different than what the directive allows. As a manufacturer, you need to consider how the end customer will respond. That is a pure business matter. The RoHS conversion tested this “on the market” concept and associated logistics. Have a discussion with your legal and financial teams. Follow the money. The process is often not clear. Hope this helps W. Richard Gartman, MS, CSP Product Stewardship Manager Texas Instruments, Education Technology 7800 Banner Drive, Dallas, Tx 75251 Office: 972-917-1636 Email: [email protected] <mailto:[email protected]> Fax: 972-917-0668 URL: www.education.ti.com <http://www.education.ti.com/> www.education.ti.com/us/productstewardship <http://education.ti.com/us/productstewardship> <http://education.ti.com/us/productstewardship> Please consider the environment before printing this email. There is only one earth - don't waste it. <http://education.ti.com/us/productstewardship> Who is John Galt? <http://education.ti.com/us/productstewardship> ________________________________ From: [email protected] [mailto:[email protected]] On Behalf Of Scott Xe Sent: Friday, August 28, 2009 11:50 AM To: [email protected] Subject: Placed on the market date Lots of Directives use “a placed on the market date”. Lots of people interpret if the products have not upgraded to the new directive, they have to arrive in EU before that date and the products can be exempted to sell it thru after the placed on the market date. Is it legally correct to the spirit of the directive? If not, what should the retailers do if they cannot sell the goods in the warehouse after the placed on the market date? Regards, Scott - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]>
