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In Europe, the manufacturer is _legally required_ to either accept old devices for recycling or contribute to a shared fund for doing this. (The program is called "WEEE": http://www.environment-agency.gov.uk/business/topics/waste/1... )



Which is an enormous racket and close to impossible to comply with economically for small manufacturers in some countries.

As an example, in Germany, if you are a small electronics manufacturer and sign up to the system, you get entered into a lottery weighted by the amount of devices (measured by weight) you ship, and whenever a container of e-waste gets filled, a randomly selected unlucky participant has to take possession of said container, no matter where it happens to be or what it's full of, and find some way to dispose of it. It's absolutely insane. In addition, you have to pay a fee to get to participate, and also you are subject to random inspections by an entity with absolutely no oversight that is legally prevented from having competitors. You have to pay for the inspections yourself too, to the same entity, which also runs said lottery.

There's no option to only accept your own devices for recycling, and also no option to contribute to a shared fund that takes care of it all. There's a small industry that will sell you INSURANCE against winning the shit lottery.


I hadn't realised it was quite that crazy.

I'm still wrestling with CE approval for a device containing a GSM module. Which looks like it's going to be about E15000 for the radio and electrical testing, plus the complexities of RoHS compliance (random lab testing required, even if all your components are certified lead-free?)

I've concluded that Tindie-style electronics cottage industry is basically illegal in the EU. Fortunately I can still buy stuff from dealextreme and alibaba that doesn't have to comply..


With a GSM module, you want a pre-approved module so you only need to do EMC testing. Doing your own radio testing is ridiculous and expensive. For RoHS compliance you should be able to get away with a declaration as long as not only the components but also the assembly process is lead-free. Incidentally, I have some thoughts on fixing this process, if you'd be willing to talk about it. Contact me on IRC (Kliment on the freenode network) or at kliment at 0xfb.com (yes, that is a zero)




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