So far I've carefully avoided getting pulled into this quagmire but a marketing type wander by with a question. I don't know his reference point but basically he was under the impression that REACH had some sort of tonnage requirement and that below that number it didn't require REACH compliance. I.E he had 200 units to send to Bulgaria and that this was below this annual tonnage value for the year.
I am presuming that any mention of tonnage is more just for tracking purposes to monitor how much of these controlled chemicals is reaching the EU on a yearly basis. An effort maybe to show reductions over time or something. I've sent him off to do the research himself and gave him some web locations where he might get the full story. Does anybody know of a "tonnage limit" by which a manufacturer may exclude small one time type of shipments. I don't even want to know what goes on in a regulators mind, but if I were one I can't imagine such a clause. That would, in my opinion, just set up the possibility where manufactures try to set up multiple low "tonnage" shipments to circumvent the requirements. Gary McInturff Reliability/Compliance Engineer Esterline Interface Technologies Featuring ADVANCED INPUT, GAMESMAN, LRE MEDICAL, and MEMTRON products 600 W. Wilbur Avenue Coeur d'Alene, ID 83815-9496 Toll Free: 800-444-5923 X1XXX Tel: (208) 635-8 Fax: (208) 635-8 www.esterline.com/interfacetechnologies<http://www.esterline.com/interfacetechnologies> Technology, Innovation, Performance... "Information in or attached to this e-mail message may be subject to export control restrictions of the International Traffic in Arms Regulations (ITAR) (22 CFR pts. 120-130) or the Export Administration Regulations (EAR) (15 CFR pts. 730-774). Before exporting this information outside the United States or releasing it to a foreign person in the United States, you need to determine whether a license under the EAR or the ITAR is required to do so. If you have any questions about this obligation, please contact me." Click here<http://www.esterline.com/governance/email_disclaimer/tabid/1532/Default.aspx> to read disclaimer - ---------------------------------------------------------------- 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://www.ieee-pses.org/list.html (including how to unsubscribe) 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]>
