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Hearing Aides RoHS Exempt?

Jan writes:

Thanks for all your help. I re-read an email that a gentleman had sent to you on March 14th trying to get a better understanding of the exemption for Medical devices. I was under the impression it is only for Medical Equipment manufacturers or Medical device implantables. I recently heard from a company who is marketing hearing aides and they were under the impression a hearing aide would be exempt…? What is your understanding?

Jan,

My first thought is, “You’ve got to be kidding.” I think it is a stretch and violates the intent of the directive. I believe directive’s intent is to exempt devices that can only be manufactured with RoHS substances or would be highly unlikely to be disposed of in a landfill. Hearing aides miss on both accounts in my opinion, but remember it is only my opinion.

Best Wishes,

Dr. Ron