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

[Dan Snazelle]

hmmm

now i am even more confused






----------------------------------------
> Subject: Re: [sdiy] Info on using vactrols with exemption in EU from metasonix
> From: ben at stuyts.nl
> Date: Wed, 16 Sep 2009 00:47:48 +0200
> CC: synth-diy at dropmix.xs4all.nl
> To: subjectivity at hotmail.com
>
> 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
>