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

[cheater cheater]

Yep, but what i really mean is: how is the vactrol-police related to
the rohs police?

isn't rohs a separate directive from the 'vactrol ban'?

not clear on that one..

Thanks
D.

On Wed, Sep 16, 2009 at 7:55 PM, Ben Stuyts <ben at stuyts.nl> wrote:
> 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
>
>