A
week ago, an AVC2 customer in Germany wrote and said customs was
refusing the AVC2 module entry into Germany. A few days later I
got the rejection note, in
German,
but the lack of compliance to European Standards was obvious. The
AVC2 came back today. The package was opened, they saw the module,
they saw the instructions, it had been inspected
So, it is time for a CE mark for the AVC2 so it can be sold in the CE
countries of Europe openly.
The units as they are today are made from RoHS compliant parts but 2
diodes still have Pb so they need that trash can with a X over it
symbol. But we will change them out for similar no Pb parts and be
able to mark it Pb Free. We need to write an engineering analysis
and a failure mode analysis. Verify and document compliance to a
bunch of European safety directives like the Low Voltage Directive
2014/35/EU,
Restriction of Hazardous Substances Directive
RoHS 2011/65/EU, that lead to Waste Electrical and
Electronic Equipment Directive WEEE 2012/19/EU… Turns out the EV
the AVC2 is used in is a vehicle so the list ends at End of life
Vehicles 202/96/EC which is a lot easier than WEEE especially if there
is no Pb. There are bunch more they checked off for batteries and
radio interference that I just need to note have nothing to do with the
AVC2. The AVC2 must have been a danger to Germany and all of
Europe based on the rejection note.
To
save the world from this threat, we will make some compliant AVC2-CE
modules. We will replace the offending diodes that contain Pb.
We will write the needed documents and we will add a CE, RoHS, REACH and
Pb free sticker to the module and equally important include a paper
declaration that covers all of the threats.
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Made In USA |
For all of you with existing modules, you have the exact same product,
with Pb in 2 diodes, no extra decal and no paper declaration. The
Pb is under 2 layers of epoxy inside the plastic box so we think you are
safe.
So
As the research was going on, I learned California needs a warning if a
product contains Pb.
Present
stock and work in progress will get a sticker Pb, and a trash can with X
over it. After they are gone, they all will be full CE, RoHS,
REACH Pb Free, sticker and a paper declaration with new diodes.
At
first the AVC2-CE will be for those who want or need it. A loose
resistor will be includer for the .r version. The AVC2 and
AC2.r will continue but not available to CE countries until all units
are compliant. In the spirit of free and open trade the AVC2-CE
will cost $45.99 as opposed to $39.99 for the existing modules.
The AVC2-CE will end when everything is compliant and the price will
return to normal.
The plan is the have the first AVC2-CE ready in mid-January December
2019. If you have time
constrains write us and need CE now write us.
If you have other regulatory needs let us know.