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

[Ben Stuyts]

On 16 sep 2009, at 22:09, cheater cheater wrote:

> 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..

Ah, ok, sorry, that's what you meant. Ok, basically the ROHS directive  
here in the EU is about reducing all kinds of potentially damaging  
chemicals: ROHS = "Restriction of Hazardous Substances". Although many  
people think this is only about lead-free solder, it is about lots of  
chemicals, including cadmium. And cadmium is one of the main  
ingredients of vactrols. So the vactrol problem is a part of the whole  
ROHS problem. Hope that clears it up.


>
> 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

Ben