Who is responsible for RoHS Declaration?

[ems07]

I work for a contract manufacturer, building other people's products. I have a customer asking me to provide a RoHS declaration for their product (that we build). I typically provide a declaration based only on our processes and materials we provide for the manufacture of the customers' products. This does not include the materials used to build the prodcuts that are provided by the customers (consigned), because we do not have purchase nor have control over it. A customer wants to provide us with all of the declarations for the materials they supply and then want us to provide an overall declaration for the finished product. This seems wrong to me as the customer should be providing the declaration for their product based on the sub-declarations we and the other suppliers provide them. I would appreciate any insight or guidance in this matter. Thanks.

 

[D_Wood]

Re: Who is responsible for RoHS declaration...

I work for a manufacturing company here in the USA whose products are built over seas. We have assigned the responsibility of collecting the supporting documentation to our manufacturing facility. They collect the RoHS documentation from their various component and material suppliers and then create the DOC. The DOC is then sent to our regulatory department for review and recording purposes. Our over seas Quality Assurance group perform routine audits of our manufacturing plants, which includes checking the RoHS supporting documentation. Hope this helps.

 

[Ronen E]

I work for a contract manufacturer, building other people's products. I have a customer asking me to provide a RoHS declaration for their product (that we build). I typically provide a declaration based only on our processes and materials we provide for the manufacture of the customers' products. This does not include the materials used to build the prodcuts that are provided by the customers (consigned), because we do not have purchase nor have control over it. A customer wants to provide us with all of the declarations for the materials they supply and then want us to provide an overall declaration for the finished product. This seems wrong to me as the customer should be providing the declaration for their product based on the sub-declarations we and the other suppliers provide them. I would appreciate any insight or guidance in this matter. Thanks.

Hi,

In my opinion it could work either way. While you may be objectively "right" (if such a thing exists ), I think in situations like these it'd be wise to factor in your relationship with the customer, and maybe go the extra mile in order to excel in your service. It all depends on the circumstances.

Cheers,
Ronen.

 

[Kales Veggie]

I work for a contract manufacturer, building other people's products. I have a customer asking me to provide a RoHS declaration for their product (that we build). I typically provide a declaration based only on our processes and materials we provide for the manufacture of the customers' products. This does not include the materials used to build the prodcuts that are provided by the customers (consigned), because we do not have purchase nor have control over it. A customer wants to provide us with all of the declarations for the materials they supply and then want us to provide an overall declaration for the finished product. This seems wrong to me as the customer should be providing the declaration for their product based on the sub-declarations we and the other suppliers provide them. I would appreciate any insight or guidance in this matter. Thanks.

It depends. What was agreed upon during the contract negotiations?

You have no control over what components your customer selected, so you can not make a RoHS compliance statement about the product.

(RoHS is about the finished product and not about the process of making that product. Your customer only "bought" the manufacturing process from you.)