Paul Whatton wrote:
>Hi Steve
>
>I don't quite follow this about secondhand and vintage equipment?
>
>Will it be illegal for example for a UK business to sell me a piece of
>secondhand or vintage equipment that is not RoHS compliant? And would
>this apply to private sales/purchases too? So, can an amateur radio
>retailer sell second-hand non-compliant equipment at-all after July?
>
>I'm thinking also about my other hobby which is vintage HiFi. There is a
>big international market in this area and gear is bought and sold
>worldwide both by private individuals and by dealers.
>Steve Thompson wrote:
>> I've used the term 'new' equipment - the wording is all about things
>> (individual items, not product lines) offered for sale for the first
>> time, and applies equally to used and vintage equipment. Personal
>> sales/purchases will be ignored, at least for the time being, but it
>> will be illegal for my business to import a piece of second hand gear
>> from outside the EU if it uses standard solder in the construction.
>>
The "lead-free" regulations will only apply to new production that is
placed on the market AFTER the cutoff date. That term "placed on the
market" has a very specific legal meaning - roughly speaking, it only
applies to commercial product lines.
For example, if a company has a product line that is continuing past the
cutoff date, all production that will be sold to an end user in the
European Union after the cutoff date must comply.
Imports of non-compliant products from outside the EU are also covered.
However, the whole world is changing over to "unleaded" construction
over the next few years, so my guess is that they won't be chasing
individual private imports until after it doesn't matter.
The regulation specifically does not apply to future re-sales of
second-hand or vintage products, wherever they come from, because those
had already been placed on the market BEFORE the cutoff date.
It also does not apply to future private sales of individual pieces of
home-made equipment, because that doesn't count as being "placed on the
market" as a product line. (However, if someone was making repeat sales
of the same product, that would eventually appear on the radar.)
I am not sure how the regulations apply to special one-off or short-run
products of the kind that Steve's company makes... but in many ways, the
problem is already solving itself. Most of the individual parts are
changing over to "unleaded" versions, and PC board manufacturers are
changing from tin/lead solder coatings to pure tin or other lead-free
materials. (Shameless plug: future supplies of Triode and Tetrode Boards
will be SILVER plated, at no increase in price :-)
When all the parts have changed over to lead-free, that leaves only the
solder itself. There are some technical problems with using lead-free
formulations, due to the higher melting point and other factors, but
they don't need to affect hams. It will still be legal for anyone to
sell, buy and USE existing leaded solders, provided they are not used on
products that are covered by the regulations.
This means that hams can continue to use regular solder to build new
equipment (there are basically no compatibility problems between
existing leaded solders and new unleaded parts). Repair shops in the EU
can continue to use leaded solder in older equipment; but they will have
to be careful to use unleaded solder on any equipment that was "born
unleaded".
I am pretty sure of the above information, which is based on recent[*]
checking by people who have gone all the way back to the authorities.
Although my legal wording may not be strictly accurate, I think the
overall conclusions about what we can or can't do are correct.
[*] There is still a lot of stuff on the web dating from a few years
ago, when many people overreacted, and also the authorities hadn't
thought through all the implications in detail. More recent sources are
taking a much more measured and reasonable tone.
Moving on into speculation, hams in Europe might see a bonanza of older
parts trickling down into the hamfests because they didn't make it into
products sold before the deadline. It will still be OK to sell parts,
because the regulations only apply to finished products... but
individual constructors will be almost the only people who would want to
buy them.
Another thought is that even though it will still be legal to sell
leaded solders, the market will shrink to a tiny fraction of its former
size, so beyond the next few years there may not be so many different
types of leaded solder still available.
--
73 from Ian GM3SEK 'In Practice' columnist for RadCom (RSGB)
http://www.ifwtech.co.uk/g3sek
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