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

[Ben Stuyts]

Jeff,

On 16 sep 2009, at 22:28, BrightBoy wrote:

> They are the same police.  The chemicals/materials inside vactrols  
> are not
> ROHS approved except for possibly military applications.

Just to be clear: the vactrols are exempt for another few months. This  
is the actual text from the list of cadmium exepmtions:

"35. Cadmium in photoresistors for optocouplers applied in  
professional audio equipment until 31st December 2009."


>
> Jeff
>
> -----Original Message-----
>> From: cheater cheater <cheater00 at gmail.com>
>> Sent: Sep 16, 2009 4:09 PM
>> To: synth-diy <synth-diy at dropmix.xs4all.nl>
>> Subject: Re: [sdiy] Info on using vactrols with exemption in EU  
>> from metasonix
>>
>> 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

Ben