| Dear Customer,
Our long-term quality strategy alone makes it a matter of course that
we implement the applicable directives and legal regulations for our
products in due time.
Of course, this also applies for the directive WEEE 2002/96/EC and
the national implementation in the German Elektro- und Elektronikgerätegesetz
of March 16 th , 2005 resulting from it.
After careful consideration of the area of application defined there,
we came to the conclusion that our products which are industrial and
medical video cameras do not belong to the area of application the
directive comprises.
Subsequently, we enclosed an extract of the statement of the German
EAR-Stiftung (Foundation waste electrical and electronic equipment
register), which you can find at the following link
http://www.stiftung-ear.de/stiftung_ear/fragen_und_antworten/anwendungsbereich_elektrog/
According to the definitions of the EU F&Q list and the EMC directive,
a device belongs to the area of application of the ElektroG if it
- fulfils an independent function desired by end user, and
- is offered as single selling unit in trade, and
- is intended for direct use by the intended end user, i.e.
- if the end user himself can put the device into operation without
installation by qualified personnel, and
- at the utmost, simple connections with other devices are required
like e.g. cable plug-in connections, and
- a manual is enclosed which is directed at the end user.
A device which is provided with the CE mark
pursuant to the law on electromagnetic compatibility (EMC) with the
utmost probability fulfils the mentioned requirements and therefore
belongs to the area of application of the ElektroG.
Components and modules do not belong to the area of application
of the
ElektroG if they do not possess the features of devices in the above
mentioned sense themselves.
Auxiliary facilities which are installed in a device but are connected
to it by simple connections usually belong to the area of application
of the ElektroG because they are to be understood as independent devices
in the above mentioned sense. For example, peripheral devices of a
PC like printer, keyboard, mouse, scanner, USB memory sticks etc. are
all independent devices which all of them independently belong to the
area of application of the ElektroG. Also auxiliary facilities which
can be installed in a device by the end user himself and which possess
an independent function are devices in the sense of the ElektroG and
belong to its area of application. Examples: drives, additional memories,
CD writers which are available in trade for the installation in a PC
by the end user.
On the basis of these considerations, we decided in favour of the
following approach
1.Our products are never passed on to end users
by NET GmbH.
2. It is true that §3 Abs. 1 ElektroG is applicable, but our
products can be operated as part of another device only and must therefore
be considered as component which does not belong to the area of application
of the ElektroG.
3. Furthermore, the products cannot be considered as end devices with
independent function (see guideline for the directive 89/336/EG [EMC
directive], chap. 3.8).
That is the reason why we did not register at EAR. Conversely, this
means that our products do neither belong to the area of application
of the RoHS (Directive on the Restriction of the Use of Certain Hazardous
Substances in Electrical and Electronic Equipment) , since this directive
in turn refers to the appendix of the directive WEEE to which we, as
aforementioned, do not belong.
Since, however, you as our customer need
products compliant to the rules, we have adapted many of our products
to the RoHS directive. Since this topic is too complicated to be recapitulated
sufficiently here, we request you to contact our Sales Department if
you have any questions.
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