Must strive to remove lawyers from this process. What is the INTENDED purpose of the REACH directive? To prevent bad stuff from entering your common market? To control concentrations of bad stuff in equipment that will eventually go to a landfill? To control exposure to bad stuff outside of a controlled environ? The technical answers to these questions will determine definition of article.
For at least Germany, the IC is an article only to the end-item mfr as received. Upon assembly, all that is soldered into the PCB cannot be considered 'reversibly' removed, so the 'article' is the PCB assembly minus all of the stuff that can be disconnect by manual means. And the German FAQ seems to rely on the principle of attachment and containment. So it seems to be dependent on the equipment's construction, per when it is placed on the market. And it also seems to depend on the whims and interpretations of each individual member state. Brian -----Original Message----- From: [email protected] [mailto:[email protected]]On Behalf Of John Woodgate Sent: Wednesday, November 28, 2012 9:54 AM To: [email protected] Subject: Re: Recent information from Germany on Once an Article Always an Article In message <dd90d4c456acb4418b0c7351e0c363b1859...@ca1exclv08.adcorp.kla-tencor.com> , dated Wed, 28 Nov 2012, "Crane, Lauren" <[email protected]> writes: >ust saw an apparent German REACH CLP helpdesk position from September >on the ?Once an Article Always an Article? The lawyers will grow even richer. Is an IC an article? Is a die an article? Is a bonding wire an article? Is an atom an article? Where does it stop? -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it proves to be. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - ---------------------------------------------------------------- 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.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. 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]>
