Re: [PSES] RoHS III references on the DoC?

2021-12-20 Thread Douglas E Powell 
Thank you everyone. As always, very informative.

-Doug


Douglas E Powell
Laporte, Colorado USA
doug...@gmail.com
LinkedIn <https://www.linkedin.com/in/coloradocomplianceguy/>

On Sun, Dec 19, 2021 at 9:05 PM Bill Owsley <
00f5a03f18eb-dmarc-requ...@listserv.ieee.org> wrote:

> And if asked to provide evidence, documents, etc backing up the
> declaration, there will be a limited time to do so.
> Management might take the position to get the doc's when asked, and hope
> that they are indeed in compliance.
> The consequence can be banned from the market for a period.
> That happened due to a manufacturing defect and insufficient quality
> control to detect the defect.
> Near a year to correct and demonstrate compliance before getting off the
> ban.
>
> So nothing moves into our distribution control without solid evidence of
> compliance.
> A letter from an importer does not suffice, but if often offered.
> Even a big time manufacturer has offered to print anything we want on the
> label.
>
>
>
> On Thursday, December 16, 2021, 3:30:12 PM EST, John Woodgate <
> j...@woodjohn.uk> wrote:
>
>
> My advice is always cite, because Mr. Militant Customs Man can challenge
> your import because there is no proof on the DoC that you have taken all
> the amendments into account. You don't need to list every amendment; 'and
> all amendments up to the date of dispatch' should be enough.
>
> ==
> Best wishes John Woodgate OOO-Own Opinions Only
> www.woodjohn.uk
> Rayleigh, Essex UK
> Istae nunc praetereunt nisi non ubicumque
>
>
>
> On 2021-12-16 20:23, Charlie Blackham wrote:
>
> Doug
>
>
>
> It’s not required – the applicable Directive is still 2011/65/EU
>
>
>
> 2015/863 Directive amended it…….as did 60 or so Commission Delegated
> Directives
>
>
>
> Whether you like it or not, declaring compliance to RoHS means that you
> are declaring compliance with RoHS, as amended, with applicable permitted
> exemptions if permitted, at the time of signing.
>
>
>
> Lots of people like ask to see it on the DoC, so I agree that it won’t
> hurt, probably isn’t “wrong”, but also is not “required”
>
>
>
> You do not however declare compliance to RoHS III (it doesn’t exist)
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/> *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* John Woodgate  
> *Sent:* 16 December 2021 20:19
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] RoHS III references on the DoC?
>
>
>
> It can't hurt to cite it. There are cases where a citation is not allowed,
> but I don't think this is one of them.
>
>
> ==
> Best wishes John Woodgate OOO-Own Opinions Only
> www.woodjohn.uk
> Rayleigh, Essex UK
> Istae nunc praetereunt nisi non ubicumque
>
>
> On 2021-12-16 19:48, Douglas E Powell wrote:
>
> All,
>
>
>
> Given that Directive 2011/65/EU has been amended by Directive (EU)
> 2015/863, is it now necessary to reference the amendment on the Declaration
> of Conformity?
>
>
>
> This is an amendment to Annex II, and "RoHS III" appears terminology used
> by the unwashed masses.
>
>
>
> Thoughts?
>
>
>
> -Doug
>
>
>
>
>
> Douglas E Powell
>
> Laporte, Colorado USA
>
> doug...@gmail.com
>
> LinkedIn <https://www.linkedin.com/in/coloradocomplianceguy/>
>
> -
> 
>
> 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 <
> emc-p...@ieee.org>
>
> 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) <http://www.ieee-pses.org/list.html>
> List rules: http://www.ieee-pses.org/listrules.html
>
> For help, send mail to the list administrators:
> Scott Douglas 
> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bache

Re: [PSES] RoHS III references on the DoC?

2021-12-19 Thread Bill Owsley 
 And if asked to provide evidence, documents, etc backing up the declaration, 
there will be a limited time to do so.
Management might take the position to get the doc's when asked, and hope that 
they are indeed in compliance.
The consequence can be banned from the market for a period.
That happened due to a manufacturing defect and insufficient quality control to 
detect the defect.
Near a year to correct and demonstrate compliance before getting off the ban.

So nothing moves into our distribution control without solid evidence of 
compliance.
A letter from an importer does not suffice, but if often offered.
Even a big time manufacturer has offered to print anything we want on the label.



On Thursday, December 16, 2021, 3:30:12 PM EST, John Woodgate 
 wrote:  
 
  
My advice is always cite, because Mr. Militant Customs Man can challenge your 
import because there is no proof on the DoC that you have taken all the 
amendments into account. You don't need to list every amendment; 'and all 
amendments up to the date of dispatch' should be enough.
 
 
==
 Best wishes John Woodgate OOO-Own Opinions Only
 www.woodjohn.uk
 Rayleigh, Essex UK
 Istae nunc praetereunt nisi non ubicumque
 
 
 
  On 2021-12-16 20:23, Charlie Blackham wrote:
  
 
 
Doug
 
  
 
It’s not required – the applicable Directive is still 2011/65/EU
 
  
 
2015/863 Directive amended it…….as did 60 or so Commission Delegated Directives
 
  
 
Whether you like it or not, declaring compliance to RoHS means that you are 
declaring compliance with RoHS, as amended, with applicable permitted 
exemptions if permitted, at the time of signing.
 
  
 
Lots of people like ask to see it on the DoC, so I agree that it won’t hurt, 
probably isn’t “wrong”, but also is not “required”
 
  
 
You do not however declare compliance to RoHS III (it doesn’t exist)
 
  
  
Best regards
 
Charlie
 
  
 
Charlie Blackham
 
Sulis Consultants Ltd
 
Tel: +44 (0)7946 624317
 
Web: https://sulisconsultants.com/  
 
Registered in England and Wales, number 05466247
  
  
   
From: John Woodgate  
 Sent: 16 December 2021 20:19
 To: EMC-PSTC@LISTSERV.IEEE.ORG
 Subject: Re: [PSES] RoHS III references on the DoC?
   
  
 
It can't hurt to cite it. There are cases where a citation is not allowed, but 
I don't think this is one of them.
  
==
 Best wishes John Woodgate OOO-Own Opinions Only
 www.woodjohn.uk
 Rayleigh, Essex UK
 Istae nunc praetereunt nisi non ubicumque
 
 
 
   
On 2021-12-16 19:48, Douglas E Powell wrote:
  
   
All,
   
  
   
Given that Directive 2011/65/EU has been amended by Directive (EU) 2015/863, is 
it now necessary to reference the amendment on the Declaration of Conformity?  
   
  
   
This is an amendment to Annex II, and "RoHS III" appears terminology used by 
the unwashed masses. 
   
  
   
Thoughts?

  
   
-Doug
   
  
   
  
  
Douglas E Powell
   
Laporte, Colorado USA
   
doug...@gmail.com
   
LinkedIn
 
-

 
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 List rules: http://www.ieee-pses.org/listrules.html 
 
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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)
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Re: [PSES] RoHS III references on the DoC?

2021-12-16 Thread John Woodgate 
My advice is always cite, because Mr. Militant Customs Man can challenge 
your import because there is no proof on the DoC that you have taken all 
the amendments into account. You don't need to list every amendment; 
'and all amendments up to the date of dispatch' should be enough.


==
Best wishes John Woodgate OOO-Own Opinions Only
www.woodjohn.uk
Rayleigh, Essex UK
Istae nunc praetereunt nisi non ubicumque



On 2021-12-16 20:23, Charlie Blackham wrote:


Doug

It’s not required – the applicable Directive is still 2011/65/EU

2015/863 Directive amended it…….as did 60 or so Commission Delegated 
Directives


Whether you like it or not, declaring compliance to RoHS means that 
you are declaring compliance with RoHS, as amended, with applicable 
permitted exemptions if permitted, at the time of signing.


Lots of people like ask to see it on the DoC, so I agree that it won’t 
hurt, probably isn’t “wrong”, but also is not “required”


You do not however declare compliance to RoHS III (it doesn’t exist)

Best regards

Charlie**

**

*Charlie Blackham*

*Sulis Consultants Ltd*

*Tel: +44 (0)7946 624317*

*Web: https://sulisconsultants.com/ *

Registered in England and Wales, number 05466247

*From:*John Woodgate 
*Sent:* 16 December 2021 20:19
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] RoHS III references on the DoC?

It can't hurt to cite it. There are cases where a citation is not 
allowed, but I don't think this is one of them.


==
Best wishes John Woodgate OOO-Own Opinions Only
www.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK
Istae nunc praetereunt nisi non ubicumque


On 2021-12-16 19:48, Douglas E Powell wrote:

All,

Given that Directive 2011/65/EU has been amended by Directive (EU)
2015/863, is it now necessary to reference the amendment on the
Declaration of Conformity?

This is an amendment to Annex II, and "RoHS III" appears
terminology used by the unwashed masses.

Thoughts?

-Doug

Douglas E Powell

Laporte, Colorado USA

doug...@gmail.com <mailto:doug...@gmail.com>

LinkedIn <https://www.linkedin.com/in/coloradocomplianceguy/>

-


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 

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
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List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
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All emc-pstc postings are archived and searchable on the web at: 
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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 
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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 


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 
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graphics (in well-used formats), large files, etc.


Website: http://www.

Re: [PSES] RoHS III references on the DoC?

2021-12-16 Thread Charlie Blackham 
Doug

It’s not required – the applicable Directive is still 2011/65/EU

2015/863 Directive amended it…….as did 60 or so Commission Delegated Directives

Whether you like it or not, declaring compliance to RoHS means that you are 
declaring compliance with RoHS, as amended, with applicable permitted 
exemptions if permitted, at the time of signing.

Lots of people like ask to see it on the DoC, so I agree that it won’t hurt, 
probably isn’t “wrong”, but also is not “required”

You do not however declare compliance to RoHS III (it doesn’t exist)

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: John Woodgate 
Sent: 16 December 2021 20:19
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RoHS III references on the DoC?


It can't hurt to cite it. There are cases where a citation is not allowed, but 
I don't think this is one of them.
==
Best wishes John Woodgate OOO-Own Opinions Only
www.woodjohn.uk<http://www.woodjohn.uk>
Rayleigh, Essex UK
Istae nunc praetereunt nisi non ubicumque


On 2021-12-16 19:48, Douglas E Powell wrote:
All,

Given that Directive 2011/65/EU has been amended by Directive (EU) 2015/863, is 
it now necessary to reference the amendment on the Declaration of Conformity?

This is an amendment to Annex II, and "RoHS III" appears terminology used by 
the unwashed masses.

Thoughts?

-Doug


Douglas E Powell
Laporte, Colorado USA
doug...@gmail.com<mailto:doug...@gmail.com>
LinkedIn<https://www.linkedin.com/in/coloradocomplianceguy/>
-


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All emc-pstc postings are archived and searchable on the web at:
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Re: [PSES] RoHS III references on the DoC?

2021-12-16 Thread John Woodgate 
It can't hurt to cite it. There are cases where a citation is not 
allowed, but I don't think this is one of them.


==
Best wishes John Woodgate OOO-Own Opinions Only
www.woodjohn.uk
Rayleigh, Essex UK
Istae nunc praetereunt nisi non ubicumque



On 2021-12-16 19:48, Douglas E Powell wrote:

All,

Given that Directive 2011/65/EU has been amended by Directive (EU) 
2015/863, is it now necessary to reference the amendment on the 
Declaration of Conformity?


This is an amendment to Annex II, and "RoHS III" appears terminology 
used by the unwashed masses.


Thoughts?

-Doug


Douglas E Powell
Laporte, Colorado USA
doug...@gmail.com
LinkedIn 
-


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 


All emc-pstc postings are archived and searchable on the web at: 
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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 
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List rules: http://www.ieee-pses.org/listrules.html

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[PSES] RoHS III references on the DoC?

2021-12-16 Thread Douglas E Powell 
All,

Given that Directive 2011/65/EU has been amended by Directive (EU)
2015/863, is it now necessary to reference the amendment on the Declaration
of Conformity?

This is an amendment to Annex II, and "RoHS III" appears terminology used
by the unwashed masses.

Thoughts?

-Doug


Douglas E Powell
Laporte, Colorado USA
doug...@gmail.com
LinkedIn 

-

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 


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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)
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For help, send mail to the list administrators:
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