Certificate of compliance to RoHS/REACH/WEEE - any such animal?

rstocum

Involved In Discussions
#1
It is that time of year that I get quality surveys from customers. This latest one is particularly vexing. It is from a prospective new customer for whom we manufacture nothing as yet. It asks if our company is RoHS, REACH, and WEEE compliant, and then requests that the proper certificate of compliance be attached. I can see putting RoHS/REACH on a certificate of compliance for parts we manufacture, but a certificate of compliance for the company to submit as a blanket cert for all of our parts/processes I have not seen before. I was under the impression that the RoHS/ REACH requirements were based on content of substances in or on the product. I find no examples on the world wide interwebs of a blanket cert for this kind of thing. Does anyone have any knowledge of this type of certificate of compliance? Should I add a compliance statement for these things to our generic C of C, and offer that as an example of how we certify compliance?
 
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Ninja

Looking for Reality
Trusted Information Resource
#2
I don't know WEEE...but I've seen many RoHS and REACH certs...all are for products, not sites.
Have you discussed this with the customer asking for it? Perhaps they don't know what they're talking about...and you can improve the sales relationship by discussing with them.
 

rstocum

Involved In Discussions
#5
Possible unhappy new development. I put together a generic statement of RoHS/REACH as it applies to my company's products. A long standing customer asks us to submit RoHS/REACH compliance information to an online portal annually. My generic statement is based on what we have submitted to them in the past. That customer is requesting that I re-submit what I just submitted last month. No explanation as to why. I am thinking that the generic statement isn't good enough anymore, and they want something more. Statement attached. Is there anything glaring that I need to add, or change the wording?
 

Attachments

Ninja

Looking for Reality
Trusted Information Resource
#6
I don't know your customer, but I would not accept that.

It is RoHS/REACH Compliant, or it isn't. Which of those two things is true is measured by data.

"we will provide material certifications indicating compliance of the material to RoHS/REACH directives" great, provide it. That's what they are asking for.
"who provide RoHS/REACH compliance letters at request", it has been requested, provide them.
"We do not believe...", can't do anything with that...need data, go get it.

Look at what the customer buys, write a specific statement about those products based on the data. That should serve you better...
HTH
 

Kimmy

Involved In Discussions
#7
I wouldn't accept that either. Most of our customers send me their form to complete but when they don't, I put a statement on our letterhead like this.

Certificate of Conformance


Part Number(s): xxxxx

Date: xxxxx

(company name) certifies that the part(s) comply with the following environmental regulation(s):

Regulation (EC) NO 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). The articles do not contain any substances found on the most recent Candidate List of Substances of Very High Concern dated July 16, 2019.

This cert would have to be updated every time they add to the Candidate List.

If the cert was for RoHS then I say:

Certificate of Conformance

Part Number(s): xxxxx

Date: xxxxx

(company name) certifies that the part(s) comply with the following environmental regulation(s):

The RoHS 3 Directive 2015/863, no exemptions used.

If they complied with exemption(s) then I would state what exemption(s) applied.
 

Ronen E

Problem Solver
Staff member
Moderator
#8
@rstocum
At customer request, we will provide material certifications indicating compliance of the material to RoHS/REACH directives, if compliant material is quoted.
Except in specific cases that seem N/A to your situation, RoHS and REACH compliance is not by materials but by products ("Articles" in REACH language).
I'm generally with Ninja and Kimmy.
 

mattador78

Involved In Discussions
#10
The statement about your subcontractors processing with chromates means that you are having restricted substances applied to your products. As a finishing company we supply as you state on request the chemicals which are Reach Rosh and Weee restricted, also we keep a live update on our website providing that information is a good starting point
 
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