Within my circles, the people dealing with RoHS is mostly freaking out about the documentation requirement to show or prove compliance of purchased components, assemblies, and materials.
The EN 50581:2012 standard calls out three document types that is acceptable for this purpose: 1. Supplier Declarations or Signed Contractual Agreements (note it does not say "manufacturer declaration") 2. Material Declarations providing specific content information 3. Analytical Test Report Realistically, what would a Supplier Declaration or Signed Contractual Agreement look like? For small companies like ours, we purchase very few parts directly from the manufacture so we rely on distribution or resellers (suppliers). The documentation we generally get to show RoHS compliance is: Labeling on the part itself Data Sheets Information in Catalog Information in Manual Website Information Emails Our legal advisors feel that agency marks or compliance logos, symbols or statements on products, data sheets or other published documentation is a legal statement or declaration from the manufacturer. This is why companies can be sued for making false statements in such mediums. So would you agree that a RoHS marking or statement on such documents would satisfy the documentation requirement of the directive/standard? Purchase Prints Additionally, our company purchases all parts from a Purchase Print document which includes "RoHS compliant" requirements on the parts we need. Again, our legal advisors feel that Purchase Prints become a Contractual Agreement with our suppliers. We also have a Supplier Acceptance Program within our Purchasing Department which approves suppliers based on a list of quality requirements. So would you agree that a Purchase Print showing a part must be RoHS compliant would satisfy the documentation requirement of the directive/standard? Any other comments or suggestions? The Other Brian ________________________________ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
