[sdiy] Info on using vactrols with exemption in EU from metasonix

[Ben Stuyts]

Dan,

With all respect to Eric, but this is just plain silly. I've been  
through this route for non-musical instruments related equipment, so I  
will comment below from this experience:

On 15 sep 2009, at 17:16, Dan Snazelle wrote:

> You are being misinformed by a lot of fools.

Hum...

> If you need the exemption, you take it yourself,

This is true. No need to apply for it somewhere. A lot of the ROHS,  
WEEE and even the whole CE declaration can be based on your own  
declaration of conformity. Just be ready to back it up. There's a lot  
of due diligence involved.

> and include a
> preprinted ROHS certificate in every package sent to Europe. Just  
> claim
> that your products are "meant to expand the capacity of and/or  
> upgrade"
> older equipment, since your products are for use as additions to a
> "professional recording studio", which qualifies them as "upgrades".
>
> This is the exemption I take :
>
> "METASONIX takes the exemption provided in Section 7 of the Annex of  
> the
> European Union’s Restriction on the Use of Hazardous Substances in
> Electrical and Electronic Equipment (“RoHS”) Directive, 2002/95/EC:
>
> --replacement components that expand the capacity of and/or upgrade of
> EEE placed on the market before 1 July 2006.
>
> --Lead in glass of cathode ray tubes, electronic components and
> fluorescent tubes."

The directive states:

"The RoHS Regulations do not apply: ... To spare parts for the repair  
of EEE (Electrical and Electronic Equipment) that was placed on the  
market before 1 July 2006. It should be noted that, following  
discussions in the TAC, the European Commission and Member States have  
agreed that this exemption extends to parts that expand the capacity  
of and/or upgrade EEE placed on the market before that date provided  
the EEE concerned is not put on the market as a new product."

This is what I mentioned in one of my previous emails. You can use it  
for spare parts, etc. Ok, so Eric has a very wide interpretation of  
all this. If we follow his logic, this means that I could manufacture  
a bunch a loudspeakers full of lead, cadmium and all the other good  
stuff, as this qualifies as an upgrade to the other equipment in a  
living room. (As long as all the other equipment is from before 2006.)

> Given the small quantities you are making, you DO NOT have to worry
> about ROHS. It was intended to keep consumer products containing lead
> and cadmium out of the waste stream, and IS NOT intended to control
> sales or shipments of specialized, low-production music equipment. The
> ROHS law is full of long lists of exemptions for things like military
> electronics, commercial communications equipment, and many other
> specialist products. There are several more you could probably take,
> besides the ones I use.
>
> I'm still using lead solder, as well as plenty of Vactrols, and have
> never had the slightest problem shipping to Europe--and btw, I think
> Analogue Systems is also taking the same exemption, and still uses  
> lead
> solder. Lead-free solder has a lot of disadvantages.
>
> Feel free to post this to DIY or elsewhere. And stop worrying.

The directives are easily googled. No need to ask biased manufacturers  
who need to keep their sales of non-ROHS compliant equipment going.  
(Again, with all respect for the Metasonix equipment, just not  
agreeing with the ROHS pov.)

Ben