RoHS Compliance - Steel - Customer wants additional samples tested

[juliov]

Hello Quality partners, need your wise advice and opinion:

Our steel suppliers are RoHS compliant and have provided to us each a letter of Certificate of Conformance stating "this letter is intended to be a certificate of compliance for material that is supplied meeting standards for RoHS compliance. Based on information from the producing mill in the MSDS reports and the chemical composition of the material, there is a 0% concentration of the following elements: Cr+6, Pb, Hg, Cd."

Now we have a customer that still wants our company to send samples of our steel for testing to a laboratory for further analysis which is very expensive. I believe this is redundand and not needed because our steel suppliers are already ensuring to us with their COC's about RoHS compliance, any issues of nonconpliance could be traced back to the steel suppliers.

Our customers are really pushing for this extra testing, I am trying to find a persuasive argument to convince them to change their mind and accept our COC's. What are your opinions?

Thanks in advance you quality partners..

[CycleMike]

Originally Posted by juliov

Now we have a customer that still wants our company to send samples of our steel for testing to a laboratory for further analysis which is very expensive. I believe this is redundand and not needed because our steel suppliers are already ensuring to us with their COC's about RoHS compliance, any issues of nonconpliance could be traced back to the steel suppliers.

I'd offer your customer a price qoute for the extra testing.

Mike

[Al Rosen]

Originally Posted by juliov

Hello Quality partners, need your wise advice and opinion:

Our steel suppliers are RoHS compliant and have provided to us each a letter of Certificate of Conformance stating "this letter is intended to be a certificate of compliance for material that is supplied meeting standards for RoHS compliance. Based on information from the producing mill in the MSDS reports and the chemical composition of the material, there is a 0% concentration of the following elements: Cr+6, Pb, Hg, Cd."

Now we have a customer that still wants our company to send samples of our steel for testing to a laboratory for further analysis which is very expensive. I believe this is redundand and not needed because our steel suppliers are already ensuring to us with their COC's about RoHS compliance, any issues of nonconpliance could be traced back to the steel suppliers.

Our customers are really pushing for this extra testing, I am trying to find a persuasive argument to convince them to change their mind and accept our COC's. What are your opinions?

Thanks in advance you quality partners..

A C of C is not enough. Where is the data to back it up? Get the data from you supplier.

[Jim Wynne]

Originally Posted by juliov

Our steel suppliers are RoHS compliant and have provided to us each a letter of Certificate of Conformance stating "this letter is intended to be a certificate of compliance for material that is supplied meeting standards for RoHS compliance. Based on information from the producing mill in the MSDS reports and the chemical composition of the material, there is a 0% concentration of the following elements: Cr+6, Pb, Hg, Cd."

Your suppliers are allegedly RoHS (Restriction of Hazardous Substances) compliant. What objective evidence do you have?

Originally Posted by juliov

Now we have a customer that still wants our company to send samples of our steel for testing to a laboratory for further analysis which is very expensive. I believe this is redundand and not needed because our steel suppliers are already ensuring to us with their COC's about RoHS compliance, any issues of nonconpliance could be traced back to the steel suppliers.

In general, CoC's are worthless in terms of providing objective evidence of anything. Suppose your company wanted to become ISO-registered. Do you suppose that you could send the registrar a Certificate of Compliance and thus avoid an actual audit?

Originally Posted by juliov

...I am trying to find a persuasive argument to convince them to change their mind and accept our COC's. What are your opinions?

I don't think that what your customers are asking is unreasonable. They specify that the materials you use must be RoHS compliant. They want objective evidence to substantiate your claim of compliance. In a case such as this, objective evidence comes from independent testing.

This is a matter of contract review. You may be able to work up the cost of testing and negotiate sharing it with the customer(s), but don't count on it.

[ScottK]

Do you get material certs from you supplier?
A C of C and Material Certs should be enough.

If they still insist on the testing tell them you'll have to work the testing costs into the price.

[Al Rosen]

Originally Posted by CycleMike

I'd offer your customer a price qoute for the extra testing.

Mike

Not acceptable. If you are making a claim, you need data to back it up.

[ScottK]

Originally Posted by Jim Wynne

In general, CoC's are worthless in terms of providing objective evidence of anything. Suppose your company wanted to become ISO-registered. Do you suppose that you could send the registrar a Certificate of Compliance and thus avoid an actual audit?

I dunno - we satisfy our customers with a blanket RoHS statement and material certs provided by brass and steel suppliers.

And our customer are pretty compliance savvy (large medical device companies).

[Jim Wynne]

Originally Posted by Discordian

I dunno - we satisfy our customers with a blanket RoHS statement and material certs provided by brass and steel suppliers.

And our customer are pretty compliance savvy (large medical device companies).

Companies are free, in general, to set the bar as high or low as they please, notwithstanding regulatory requirements. Juliov's customers are (understandably) asking for objective evidence. I should also point out that if PPAP (a la AIAG) is involved, the manual specifically states that "the organization" is responsible for testing.

From the AIAG PPAP manual, Fourth Edition, page 6:

The organization shall perform tests for all parts and product materials when chemical, physical, or metallurgical requirements are specified by the design record or Control Plan.