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

[cheater cheater]

Ben,
I think it's very relevant to ask you how all this relates to the
vactrol police.

Cheers
D.

On Tue, Sep 15, 2009 at 11:47 PM, Ben Stuyts <ben at stuyts.nl> wrote:
> 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
>
>
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