Piotr,

Reading the EU Commission's FAQ on RoHS2 might help you 
http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf.
Components (i.e. things not intended for direct sale to the end user) are not 
considered to be in scope of RoHS (even though they fit the definition of EEE). 
It has to do with the concept of "finished product".

So, if you are going to be using the 100pcs of resistors in your product, you 
should constrain your supplier with a contract that requires them to be RoHS 
compliant, but you do not need a DoC from them.

Regards,
Lauren Crane
KLA-Tencor

From: Piotr Galka [mailto:[email protected]]
Sent: Wednesday, November 13, 2013 8:27 AM
To: [email protected]
Subject: [PSES] EN 50581 part/range of parts

To English language standard experts,

How do you understand "specific part" and "specific range of parts" in last 
sentence in EN 50581:2012 Cl. 4.3.3 (a):
"Such declarations ... shall cover a specific ... part ... or a specific range 
of ... parts..."

According to:
- directives understanding of putting product on the market (not type but 
single piece),
- direct meaning of the words (as I fill them),
it looks that:
part = this one single part,
range of parts = some (specified) number of the same type parts.

If it is true I see problems with ROHS DoC.
If I buy 100pcs of 0603 1k resistors should I ask the supplier for sending me 
the declaration for specified range of these 100pcs ?
And the same for all 200 other types of elements ?

The other way of understanding is:
part = part type (resistor 0603 1k)
range of parts = range of part types (resistor 0603 from 1ohm to 10Mohm)

This looks more logical for someone trying to make ROHS DoC but:
If they wonted to say "part type" or "range of part types" they would certainly 
said that. As they didn't said that I think they had the previous understanding 
in mind.

What is the solution I don't see ?

Best Regards
Piotr Galka
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