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

[Ben Stuyts]

Hi D.,

On 16 sep 2009, at 09:46, cheater cheater wrote:

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

It's just background info. I thought I'd inject some info from the  
rulebooks, but obviously anyone can decide for themselves what to do  
with it.

The relevance for now: until december 2009, no problems with Vactrols  
for pro audio applications. After that: lets hope for an extension.

Oh, btw, this is a good site to keep an eye on these extensions:
http://www.rohs.gov.uk/

The exemption for the Vactrols is described here:
http://www.rohs.gov.uk/Docs/Exemptions%20without%20link%20backs/RoHS%20Exemptions%20-%20Cadmium%20(2).pdf

>
> 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

Ben