Of course, RoHS applies to all otherwise-in-scope second-hand products made at 
any time that are newly placed on the EU market (from a per-unit perspective, 
not a per-model line perspective). 

It has recently been interpreted (by Commission and other authorities) as 
prohibiting the resale of any in-scope but out-of-compliance EEE after July 
2019 because of an awkward wording in Article 2(2) --> i.e., no grandfathering 
even for items already on the market.  There is a project afoot to possibly 
amend this concern (a public consultation recently closed about this, I 
believe). 

Regards,
Lauren Crane
KLA-Tencor


-----Original Message-----
From: John Woodgate [mailto:[email protected]] 
Sent: Tuesday, May 20, 2014 10:48 AM
To: [email protected]
Subject: Re: [PSES] RoHS on Hardware

In message <[email protected]>,
dated Tue, 20 May 2014, John Cotman <[email protected]>
writes:

>Yes, equipment imported for own use does not need to be RoHS compliant 
>as you say.  What happens when the importer no longer needs it is an 
>interesting question, though.  It would seem that it can't legally be 
>sold, but it can be thrown away.  This is rather perverse, given that 
>environmental legislation generally would favour reuse.

Does the Directive apply to second-hand products, including those made before 
the Directive came into effect?
>
>RoHS a really daftly structured directive.

Indeed, but of course the authorities will not admit it. But after ten years or 
so, something is changed. Look at what happened with after-market product EMC 
and the Automotive Directive.

Now, if 'hi-fi' separates come back into fashion, everything except the tuner 
will be under the EMC Directive, but the tuner will be under the RTED, which 
apparently means that CISPR 32 and 35 won't apply, despite having full EMC 
requirements for tuners.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Nondum ex 
silvis sumus John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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