Don writes:
Dr. Ron,
At the following link, I saw this:
Q: What should I do with my inventory of non-RoHS compliant products after July 2006?
A: As long as these products were placed on the EU market before the July 2006 deadline, you can keep on selling them after.
I was told the opposite. After July 1st, they have to be RoHS compliant. Which is true?
Thanks (again),
Don
Kay Nimmo of Soldertec answers:
It all depends on how you see "putting on the market" and different people will see it differently.
It is pretty clear for example that if something is in a shop before July but actually sold after July then it does not have to be RoHS compliant.
So....this is right.....
A: As long as these products were placed on the EU market before the July 2006 deadline, you can keep on selling them after.
.....but then you might need a lawyer to decide whether you have placed something on the market or not! [ What is in a Name? -- Regulation of Electrical and Electronic Products 185 KB PDF ]
All the best,
Kay
Dr. Ron comments:
After reading the document that Kay refers to, it is clear that everyone is struggling with the definition of "put on the market" as Don's question would suggest. I think the safe approach is to use what I call the "Doctrine of Noble Intent." If you use a definition of "put on the market" that would appear to be "cheating" you will likely get in trouble. You have violated the doctrine of noble intent. E.g. you flood your European distributors with 9 months worth of non-RoHS compliant inventory on June 30. An action like this will clearly lead to difficulties.
Cheers,
Dr. Ron