A lot of the World is mucho loco, but Authorities and Customers (such as yourselves when buying from suppliers!) look for clear statements of situations - and any wording that is unclear or ambiguous just leads to the reader being uncertain as to what it means!
I know that if I now received a DoC quoting 2002/95/EC then I would probably reject it because I would be looking for reference to 2011/65/EU - the supplier might just know enough to reference Art 26 and then quote it, but I'm pretty sure that most won't. Also, if a supplier isn't savvy enough to realise that he needs to keep his "public" paperwork up to date, then what do you think are the chances that his "private" paperwork - and all that needs to go on below that to support it - will be like? As they say, "first impressions count", and if they do fail to impress then there is the immediate feeling that "all is probably not well" with this company! I've "been there" many times with compliance files, test reports, DoCs / ISO 9001 audits, etc., in/from (far too!) many companies, and that feeling of uneasiness has generally been found to be justified when I started asking more probing questions :-(. John Allen -----Original Message----- From: Brian Oconnell [mailto:[email protected]] Sent: 21 November 2014 22:25 To: [email protected] Subject: Re: [PSES] RoHS directive The boys in our Tijuana factory were asking why so many suppliers' regulatory/compliance docs were hosed. Could only reply that el mundo esta mucho loco. Brian From: John Allen [mailto:[email protected]] Sent: Friday, November 21, 2014 1:57 PM To: [email protected] Subject: Re: [PSES] RoHS directive And then I re-read it and see that you could interpret a DoC to mean that reference to 2002/95/EC means that the declaration is NOT a reference to 2011/65/EU! Most confusing if you don’t know of Art 26 – in which case an Authority could reject it as out of date!! Thus I would strongly recommend that only 2011/65/EU be stated. John Allen From: John Allen [mailto:[email protected]] Sent: 21 November 2014 20:18 To: [email protected] Subject: Re: [PSES] RoHS directive Agreed- see Article 26 “Repeal” of 2011/65/EU, (RoHS 2) which states: “Directive 2002/95/EC as amended by the acts listed in Annex VII, Part A is repealed with effect from 3 January 2013 without prejudice to the obligations of the Member States relating to the time limits for transposition into national law and application of the Directive set out in Annex VII, Part B. References to the repealed acts shall be construed as references to this Directive and shall be read in accordance with the correlation table in Annex VIII.” No argument there! John Allen Compliance with Experience. West London UK From: Charlie Blackham [mailto:[email protected]] Sent: 21 November 2014 19:54 To: [email protected] Subject: Re: [PSES] RoHS directive Brian 2002 version is obsolete and should not be referenced ( it wasn't a CE marking directive either) Regards Charlie Sent from my mobile ________________________________________ From: Brian Oconnell Sent: 21/11/2014 19:43 To: [email protected] Subject: [PSES] RoHS directive The boss questioned the way declarations are written after looking at some other's documents where their D of C is worded thus: "Directive 2002/95/EC (and its amendments and 2011/65/EU)" Is not the RoHS directive now 2011/65 ? Is the 2002/95 stuff considered not obsolete? Any good reason to reference 2002/95? http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:174:0088:011 0:en:PDF Brian - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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