Nick, Not the Commission per se. The point was mentioned in a public consultation document put out by Oeko Institut (I assume at the direction of the Commission), link provided below, and "offending" paragraph as follows
" As a consequence of the current wording, non-compliant products that have been placed on the market3 between January 2013 and July 2019, are not allowed any secondary market operations after 22 July 2019." http://rohs.exemptions.oeko.info/fileadmin/user_upload/RoHS_IA_2_2/Products_newly_in_scope/Questionnaire_Products_newly_in_scope_final.pdf There is a broader interpretation of this that has been expressed by UK NMO. Ref the slide deck posted at http://www.aham.org/ht/a/GetDocumentAction/i/61298 Which includes "Article 2.2 uses the term "make available" and not "place on the market". Non-compliant EEE on the market cannot continue to be distributed after 22 July 2019." Hope that helps.... Regards, Lauren Crane KLA-Tencor -----Original Message----- From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: Friday, May 23, 2014 6:53 AM To: Crane, Lauren Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] RoHS on Hardware Lauren, Are you able to point to anything published by the Commission on this? Nick. On 20 May 2014, at 18:15, Crane, Lauren <lauren.cr...@kla-tencor.com> wrote: > > It has recently been interpreted (by Commission and other authorities) as > prohibiting the resale of any in-scope but out-of-compliance EEE after July > 2019 because of an awkward wording in Article 2(2) --> i.e., no > grandfathering even for items already on the market. There is a project > afoot to possibly amend this concern (a public consultation recently closed > about this, I believe). > > Regards, > Lauren Crane > KLA-Tencor > > - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>