EXEMPTION
The Edmund A. Gray Company Inc, of Los Angeles, CA is in
the business of manufacturing and distributing pipe nipples and
distributing pipe fittings (flow control products) to wholesale
stocking distributors in the plumbing, irrigation and waterworks
industries. As such, our business focus and distribution
channels exempt us from the scope of conditions covered in the
EU’s RoHS Directive (2002/95/EC, as amended by 2005/717/EC and
2005/747/EC).
Reasons
1. The Edmund A Gray Company does not manufacture or distribute
electrical or electronic equipment (EEE).
2. Electrical or electronic components are not required to
fulfill the primary function of any of our products.
3. Our plumbing products are "placed on the market" (if imported
in the EU) separately from electrical and electronic equipment,
therefore are not covered by or subject to the RoHS Directive.
Use of our products in a ‘fixed installation’* would not
be construed requiring compliance with the RoHS Directive,
according to non-legally binding guidance issued by certain EU
national authorities.
*The European Commission defines ‘fixed installation’ as
a
"combination of
several equipment, systems, finished products and/or components
(hereinafter called "parts") assembled and/or erected by an
assembler/installer at a given place to operate together in an
expected environment to perform a specific task, but not
intended to be placed on the market as a single functional or
conventional unit."
None of our products can perform as a 'single functional
or conventional unit'. (i.e. a nipple or fitting cannot
perpetuate the flow of water or gas without being attached to
other equipment as part of a system) As such, our products would
necessarily be considered part of a ‘fixed installation’, which
is accepted as likely being excluded from the scope of both WEEE
and the RoHS Directive.
COMPLIANCE
The Edmund A Gray Company does not add, or cause to be
added, any of the hazardous substances, as listed in the EU’s
RoHS Directive (2002/95/EC, as amended by 2005/717/EC and
2005/747/EC) to any of our products.
The Edmund A Gray Company has inquired with our raw
materials suppliers and to the best of our knowledge, based on
their responses to us, the material(s) being supplied to us do
not exceed threshold concentration levels for the hazardous
substances listed in the RoHS directives. However, we have no
control over their manufacturing processes; Therefore, we cannot
be held responsible for changes to their processes which may
inadvertently result in changes to concentration levels.
