One nuance of the RoHS challenge, is its potential impact to the used equipment market. As recent discussions here have shown, it's hard enough to 'prove' conformance for products currently in production. Even more so for used products that will be newly on the EU market (imported). Since it seems entirely impractical to test a complicated product, much less defend it via data about components (the component data owners won't share, threw it away long ago, or are out of business), the door is closing on used in-scope equipment entering Europe.
On a related note, I attended a seminar including a presentation by the UK RoHS enforcement officer from NMO. He pointed out some oddities in the Blue Guide that impact the understanding of when something is "placed on the market". Particularly, it's not when the item is imported, but only when it is supplied to a distributor or user by the importer. And even more odd is that placing on the market does not occur if a company imports something for their own use. This is not much relief for directives that also impose requirements when something is "put in to service" (like the Machinery Directive), but RoHS does not have this. Here is the blue guide section upon which this argument hinges. (page 17) " A product is placed on the market when it is made available for the first time on the Union market. The operation is reserved either for a manufacturer or an importer i.e. the manufacturer and the importer are the only economic operators who place products on the market [46]. When a manufacturer or an importer supplies a product to a distributor [47] or an end-user for the first time, the operation is always labelled in legal terms as "placing on the market". Any subsequent operation, for instance, from a distributor to distributor or from a distributor to an end-user is defined as making available." Of course, a revision of the Blue Guide could quickly close any opportunity this odd wording might represent. Regards, Lauren Crane KLA-Tencor - ---------------------------------------------------------------- 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]>
