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

rstocum

Involved In Discussions
#11
I probably should have mentioned that material certifications and plating certifications accompany each part submission, so things have been provided already. The statement about the paint subcontractor states that the parts are processed with a non-chromate rinse, I don't see how that could be misconstrued. I like the format shared by Kimmy; that might be helpful, thank you.
 

Ninja

Looking for Reality
Trusted
#12
Thanks rstocum,

Not sure that changes any of the above answers or discussion...but good to know.

Not that (at least for RoHS and REACH...the rinse makes no difference...it's all about what is left on/in the part. If it's a paint containing reportable or banned substances, the rinse won't help much...
 
#13
This may belong in another thread.
Our REACH/RoHS and Prop 65 responses to our customers have been pretty straightforward and I have been handling that for our company for about 4 years now. Recently I have been getting request for the 3 below. Has anybody dealt with these? And, is anybody using Source Intelligence, Assent Compliance or another 3rd party to manage the compliance requests for your organizations? Searching for solutions on how to manage the compliance requests. Thank you!

Has anybody dealt with these 3?
EU Medical Device Regulation (EU MDR)

Persistant Organic Pollutants (POP).

EU Biocidal regulations
 

Ronen E

Problem Solver
Staff member
Super Moderator
#14
This may belong in another thread.
Our REACH/RoHS and Prop 65 responses to our customers have been pretty straightforward and I have been handling that for our company for about 4 years now. Recently I have been getting request for the 3 below. Has anybody dealt with these? And, is anybody using Source Intelligence, Assent Compliance or another 3rd party to manage the compliance requests for your organizations? Searching for solutions on how to manage the compliance requests. Thank you!

Has anybody dealt with these 3?
EU Medical Device Regulation (EU MDR)

Persistant Organic Pollutants (POP).

EU Biocidal regulations
What are your products?
 

Ronen E

Problem Solver
Staff member
Super Moderator
#16
A little bit of everything. Keystock, Machine Keys, Grease Fittings, Spring Pins, Groove Pins, Lifting Hardware....a lot of Zinc Plated parts.
Sounds like you're not dealing with medical devices or biocides, so -

EU Medical Device Regulation (EU MDR) - not relevant to your products

Persistant Organic Pollutants (POP) - I don't know

EU Biocidal regulations - probably not relevant to your products, I'm not sure
 

leftoverture

Involved In Discussions
#17
Guess I'm replying a little late here, but better late than never! First off, it really is impossible to make a generic statement that covers every product you make unless every product you make has the exact same composition. Second, you have to consider if you are choosing the materials or is the customer? If the customer is doing the material selection, you have no power over whether they meet ROHS or REACH. We are a job shop and use about 99% customer selected materials, therefore, our ROHS and REACH declarations are along these lines:

"To the best of our knowledge the products listed on this document do not contain any of the currently listed SVHC in concentrations of 0.1% or above. The absence of SVHC has not been verified by analysis or tests and is declared based on the information available to us from our raw material suppliers. It is the responsibility of the recipient of our products to ensure that applicable rules and legislation are observed."

When our customer ask if we are ROHS and REACH compliant, I just say "yes". When they ask for a declaration, I ask for which part number(s).

Hope this helps.
 

CharlieUK

Involved In Discussions
#18
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
There is no such thing as a "certificate of compliance" for RoHS:
- you can have an audit report for the measurements performed on a sample unit - but that is only 100% valid for that sample, which you have now destroyed (sample testing can support the RoHS DoC, but that is determined as part of the compliance process)
- the manufacturer can raise a Declaration of Conformity for specific products that they comply with RoHs
RoHS compliance, like other CE marking Directives, is a combination of assessment and process for ongoing compliance

Also, to respond to another post - there is no such Directive as RoHS III - the DoC must be to 2011/65/EU as that is the CE Marking Directive
 
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