Tree Audio Branch legal in Europe?

[ruffrecords]

Here is a review of the Tree Audio Branch:

https://www.soundonsound.com/reviews/tree-audio-branch

You can see from the pics that it uses a coupe of VTL5C2 Vactrols which contain substances banned in the EU.

The rear of the unit has no CE mark or WEEE symbol and I can see neither of these in the user manual either.

So how come this is for sale in Europe at KM?:

https://www.kmraudio.com/tree-audio-the-branch-ii-channel-strip.php

Cheers

Ian

 

[[silent:arts]]

Manley and Avalon are too still selling gear with Vactrols in the EU.
(Many others too).

My guess is they just don't care.
May I quote a well known and respected audio developer / manufacture (not using optos himself to my knowledge) from a discussion we had on Facebook about Vactrols:

Yaa, I talked to the EU about it, a woman named Pasara or something, she was on the review board of the EU when it all started. GML myself and a few others tried, but that Chinese guy... We were one of the applicants. Just put them in. Marshall does. POT them and no one will know.

 

[Majestic12]

Under EU law the distributor who imports those units is seen as the "manufacturer" when it comes to CE markings (and other regulations).
If the CE conformity is declared by the EU distributor,  sticker with the logo can be added to the units afterwards.

Concerning the Vactrol ROHS issue. It is completely ignored by everyone in real life.

 

[JohnRoberts]

Under EU law the distributor who imports those units is seen as the "manufacturer" when it comes to CE markings (and other regulations).
If the CE conformity is declared by the EU distributor,  sticker with the logo can be added to the units afterwards.

Concerning the Vactrol ROHS issue. It is completely ignored by everyone in real life.

+1 the local dealers and distributors are liable for deviation from EU standards.  SInce there are no teeth some small manufacturers just go ahead and print CE on the rear panel.

JR

 

[pucho812]

I thought there was a grandfather in clause in that older designs get to bu new designs do not but I may be wrong.

 

[JohnRoberts]

I thought there was a grandfather in clause in that older designs get to bu new designs do not but I may be wrong.

2007 doesn't predate the CE mark, and even if it did, they would have VDE and other EU safety approval agencies to satisfy.

Likely a small company just ignoring the issue and putting the liability on dealers/distributors to shoulder. Do they sell direct to end users in EU? Then they just have to worry about regulators seizing their products at a trade show.  :-[

JR

PS: Funniest thing I saw recently was a US company marking a SKU with CE... implying that it had passed some safety inspection, but the SKU was 120V domestic use only and not approved by anybody. Customers are not very sophisticated about safety approvals. 

 

[Jarno]

We have an exemption to continue to use non-RoHS compliant soldering in a few places (MRI development), but you need to apply for the exemption and show that you cannot make the product to comply with RoHS. You do have to show evidence though, and it is quite a bit of paperwork, I wonder if a small company like that is going that route (and ultimately, it makes sense to go lead-free when soldering, because materials simply become obsolete). The same goes for the vactrols, they will just become more and more expensive, but then the margin probably is significant on this type of product.

 

[living sounds]

Concerning the Vactrol ROHS issue. It is completely ignored by everyone in real life.

Well, it's ignored by everyone but Jakob:

http://www.gyraf.dk/g24/index.html

8)

 

[JohnRoberts]

Well, it's ignored by everyone but Jakob:

http://www.gyraf.dk/g24/index.html

8)

When in doubt do what is right.....

JR

 

[mattamatta]

Pro audio gear in general is very loose with standards compliance.  Many manufacturers are small builders (even the name-brand companies tend to be low volume as far as electronics manufacturing goes) and either don't know or don't care.  The industry volume is pretty small so they're not likely to get called out.

A lot of manufacturers would be hard pressed to show data to back up design specs, EMC test, standards compliance, etc. if called upon.  It tends to not have been an issue in the marketplace, so it just hasn't been addressed.

 

[pucho812]

Pro audio gear in general is very loose with standards compliance.  Many manufacturers are small builders (even the name-brand companies tend to be low volume as far as electronics manufacturing goes) and either don't know or don't care.  The industry volume is pretty small so they're not likely to get called out.

A lot of manufacturers would be hard pressed to show data to back up design specs, EMC test, standards compliance, etc. if called upon.  It tends to not have been an issue in the marketplace, so it just hasn't been addressed.

yes and often times you get various version of what is and what is not allowed. for example My comment about being grandfathered in. It was something I was told from a trusted source.  but are they correct?

 

[JohnRoberts]

Pro audio gear in general is very loose with standards compliance.  Many manufacturers are small builders (even the name-brand companies tend to be low volume as far as electronics manufacturing goes) and either don't know or don't care.  The industry volume is pretty small so they're not likely to get called out.

I guess this depends on how you define "pro audio gear". Serious established manufacturers pursue safety agency approval for simple liability concerns. At Peavey we got sued over a consumer death, but UL defended our design's safety integrity with us in court. I am pretty confident that Yamaha, Sony and other large companies that sold "pro audio products" followed the rules.

A lot of manufacturers would be hard pressed to show data to back up design specs, EMC test, standards compliance, etc. if called upon.  It tends to not have been an issue in the marketplace, so it just hasn't been addressed.

Indeed, not a concern until it is... even if a small company that ignored the rules didn't kill anybody, if they became too competitive with an established rule following company odds are they would get narc'd on. I've seen products that didn't have UL stickers get dragged out of an AES show but that was a different issue with City of LA pimping their own, on the spot approvals. :

Even besides the liability I prefer to not kill people. I could probably get away with selling my outlet tester without the expensive UL certification process but I choose not to.

I am not aware of rules being grandfathered in, while if regulations change, they might grant a variance for finished goods already finished and stickered. I had to wrestle with UL once when they wanted me to pull finished goods from a warehouse to add an internal fuse stickers, that nobody was likely to ever see.  The inspector's boss was more reasonable than that inspector. (But I did jack up the factory pukes who didn't place the required fuse stickers  : and made sure it never happened again. )

JR

PS: regarding different versions of what is allowed, back last century when power amps first grew large enough to exceed the nominal continuous current ratings for outlets and line cords, one UL office was accepting conventional line cords allowing for the reduce duty cycle of real world music power, while the other UL office was still asking for 30A camper plugs.  I called and suggested they get their stories straight (which they did eventually accepting the more reasonable line cords at both offices).

 

[ruffrecords]

yes and often times you get various version of what is and what is not allowed. for example My comment about being grandfathered in. It was something I was told from a trusted source.  but are they correct?

This may be related to harmonisation. When I first got into the design of consumer electronics back in the 80s, the safety and EMC standards varied very much according to the country in which you were trying to sell. It was even worse for telephony products because every country had its own telephone monopoly who wrote the rules for that country. But even then, steps were bing taken towards harmonisation of standards; this is making a common set of standards that apply in many countries. This process has made huge strides in the intervening years and today there is very little difference in the safety standards for electronic consumer products throughout the world. EMC still has some way to go. Standards regarding generated interference are pretty much harmonised but susceptibility has some way to go - for example FCC has no requirement for susceptibility whereas in Europe mandatory standards exist.

As the harmonisation precess progressed there was considerable overlap so there were definite periods of several years where it was permissible to sell product that met the old standards until a specific date when the new standards had to be met. This is still true as the standards themselves evolve.

Cheers

Ian

 

[pucho812]

but that was a different issue with City of LA pimping their own, on the spot approvals. :

Somethings never change.

 

[Jarno]

When in doubt do what is right.....

JR

I do agree with Jakob, but it is important to note that this is not the only way. You need to have a clear plan for dealing with RoHS compliance. Leasing the non-compliant part is one way, having a field change order to replace them when a better part becomes available is another. But you will still need to show (in both cases) that you are working on a replacement, and that there is no compliant part available which is able to fulfill the function.
Regardless, to not distinguish between something that is likely to be used indefinitely, like studio equipment (but also our medical equipment) and something which is thoughtlessly discarded like consumer equipment is crazy, especially seen the tiny amounts of it. And then there's the fact that it does not apply to the automotive industry, even more mindboggling given the sheer scale of that industry, and the likelyhood of those materials ending up somewhere in the environment.

 

[JohnRoberts]

Regardless, to not distinguish between something that is likely to be used indefinitely, like studio equipment (but also our medical equipment) and something which is thoughtlessly discarded like consumer equipment is crazy, especially seen the tiny amounts of it. And then there's the fact that it does not apply to the automotive industry, even more mindboggling given the sheer scale of that industry, and the likelyhood of those materials ending up somewhere in the environment.

Classic government decision making.... sounds like a good idea but weak on science and practical perspective, heavy on crony capitalism to exempt constituencies with influence.

JR

 

[john12ax7]

Weren't the vactrols themselves also discontinued?

 

[ruffrecords]

Weren't the vactrols themselves also discontinued?

The original Perkin Elmer ones may have been but there are still plenty around. There are also other manufacturers of very similar devices.

Cheers

Ian

 

[gyraf]

The originals were all sold out in a flash, when it became apparent that exelitas were chopping up their great production line. Prices on e.g. 5C4/2 sky-rocketed into 30-50usd/pcs and were sold anyway..

Now, all you can get is chinese lookalikes. Optically, they look exactly right. Measure them, and find that they are all over the place, I can't find the slightest resemblance to the originals (and yes, I've tried a few..). Several companies will tell you that they have inherited the original manufacturing process line - and they'll sell you their vactrols with rohs-certification too  :

Jakob E.

 

[pucho812]

Yes,  they do measure all over the place.  We have ap script for matching them using old system one components.  It's time consuming as each sweep takes a minute to complete but it does allow us to separate and match them closely