RoHS Compliant Declaration - General or Detailed?

[Asherlee]

I have a very simple question.
We are asking our suppliers to provide us with a Declaration of Compliance with ROHS.

Is it sufficient for the supplier to make a GENERAL declaration that his component/material is “ROHS complaint”; or do we require a more DETAILED declaration, e.g. “samples of the product were tested and found to be within the limits specified in the Table below”:

Lead (Pb): 0.1% by weight
Mercury (Hg): 0.1% by weight
Cadmium (Cd): 0.01% by weight
Hexavalent Chromium (Cr-VI): 0.1% by weight
Polybrominated Biphenyls (PBB): 0.1% by weight
Polybrominated Diphenyl Ethers (PBDE): 0.1% by weight

Thanks.

Asherlee

[Frank T.]

Here is an example of a form that might be of some use to you.

[ScottK]

My standard approach is to send out a single statement that says that all of our parts are RoHS compliant. We hired a consultant to come in and verify this so we have back up.
This may not work for every company as other's RoHS compliance may be more part/product specific.

In a few instances we've had customers send us a specific form to complete and send back. These are not common though. Most are satisfied with the simple statement.

[Manix]

We have a standard form that we send whenever we have a request. The form has two boxes. You tick box A if it complies within the stated tolerance limits and then simply sign. OR you tick box B which states that the part does not comply and allows you to break the substances of concern down and where they exist within the part.

So I suppose that equates to a flexible form that contains within it the option to make a simple declaration.

However, we are subject to more than one regulation (ELV as well) and therefore it has to be flexible.

[Asherlee]

To all the people who replied:

Thanks for the useful information provided - much appreciated.

Asherlee

[harry]

Originally Posted by Asherlee

.............. Is it sufficient for the supplier to make a GENERAL declaration that his component/material is “ROHS complaint”; or do we require a more DETAILED declaration, e.g. “samples of the product were tested and found to be within the limits specified in the Table below”:..........
Asherlee

Whether the declaration is general or detailed, it’s the same. They are collectively termed as Self-Declaration.

Self-declaration applies to organizations whose products are covered by the RoHS directive and are able to demonstrate that they comply. To support it, you need to maintain a technical construction file (TCF) which records your reasons and decisions and all other supporting documents such as material declarations for each component or sub-component and any relevant test results, etc. In addition, you need to check RoHS compliance for the plastic, paint and surface finishes or plating.

If my liabilities are high, I would like to check the details. I’ve seen organizations (in my country) that simply copied another’s declaration note and declare that they comply – without going into the testing stage to investigate and/or confirm that their products are in compliance.

[Kales Veggie]

I would also consider before I send a certificate of RohS conformance, how do I know that my product is RohS compliant.

Lead is commonly used in electronics and alloys. Plating with Hexavalent chromium is a very common rust inhibitor.

Signing a certificate of conformance without having information from your suppliers might be a risk you should consider.

I agree with Harry. It is more than signing a CofC. You have to understand your supply chain and your internal processes from a substance aspect.