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RoHS (again)

2006-05-26 by Mark

Sorry if this is getting boring for some of you though you all seem 
to be taking this in good spirit. I've spent a happy(?) hour or so 
going through the EU pages on this. It seems there are several 
request for exemptions, these include for musical instruments with a 
lifespan of over 10 years, and for professional audio equipment. The 
EU has been asking about other technical solutions, cost 
implications etc. Funny thing is that you get to see the letters 
that have come into the EU. The musical instruments one actually 
came from a digital church organ company. The audio exemption 
request is from one company only it seems. You also see complaints 
about people not replying, asking if they had a nice holiday, their 
out of office assistants, even there "this is only for the 
recipient" type legal statements. Such is the banality of superstate 
legislation. It's not faceless eurocrats, its people not replying 
because they've been having a nice time at the seaside.

Anyway, reading the sorts of arguments people are making I think 
actually there is a case, certainly in spirit. As Grant has 
indicated there is something about volume, ie the amount of lead 
involved, the number of units..there is also something about it 
being "consumer". Looking through the list of things covered by RoHS;

"1. Large household appliances
2. Small household appliances
3. IT and telecommunications equipment
4. Consumer equipment
5. Lighting equipment
6. Electrical and electronic tools (with the exception of large-
scale stationary industrial tools)
7. Toys, leisure and sports equipment
8. Medical devices (with the exception of all implanted and infected 
products)
9. Monitoring and control instruments
10.Automatic dispensers.
11.Light bulbs, and luminaires in households"

Now under "consumer equipment" musical instruments are mentioned. 
This breaks down as
"Radio sets
Television sets
Video cameras
Video recorders
Hi-fi recorders
Audio amplifiers
Musical instruments
And other products or equipment for the purpose of recording or 
reproducing sound or images, including signals or other technologies 
for the distribution of sound and image than by telecommunications"

But I would argue when you look at the company musical instruments 
are in that this is disposable stuff. So professional studio 
equipment looks like its not really on the list, either explicit or 
implictly. If it is not on the list it is not exempt, but it is 
outside of the scope of RoHS.

regards, Mark

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