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Are FRU kits and upgrade kits impacted by RoHS?

fru impacted Kits RoHS upgrade
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Are FRU kits and upgrade kits impacted by RoHS?

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For the most part, all FRU kits, upgrades, etc must be RoHS compliant. However, spare parts used for the repair, or to the reuse, of products put on the market BEFORE July 1, 2006 are exempt. The spirit of this exemption is to prevent the premature disposal of non-RoHS equipment when it requires repair.

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