Data sheet from McMasterCarr enough for RoHS/REACH documentation?

zork_14

Starting to get Involved
#1
Hi,

I'm gathering documentation for RoHS and REACH compliance for a product I'm planning to sell. Many of my components come from McMaster Carr (MM) and the data sheet states that they are REACH and RoHS compliant. Is making a .pdf or taking a screenshot of the datasheet good enough to build my technical file? Let's for example consider this simple screw 91290A117 from MM (I cannot post a link because I'm a new user).

I've read an excerpt from EN50581:2012 (the standard that says what documents are OK for the RoHS technical file) saying that you can use:
1. a certification of compliance (CoC) from the company (with name and signature): the MM page does not have a signature.
2. a data sheet: "1. The data sheet must be from the original manufacturer". Can MM be considered as the original manufacturer?

If not, would that mean that for every MM component I should send an email to MM asking either for a certification of compliance or for the product number and manufacturer and then get the datasheet or CoC from the original manufacturer? One reason I selected McMaster is that the RoHS/REACH is so easy to check in a few clicks. I hope I do not have to go back to original manufacturers to prove my RoHS/REACH compliance.

Thanks a lot for any help
 
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Ninja

Looking for Reality
Trusted Information Resource
#2
For many, the listing (even a screen shot of the MC website offering) would be enough...but be aware that if anything ever 'hits the fan', McMaster Carr will play the "we had every reason to believe it" card, and your company will bear the burden of proof.

The drawings for the black SHCS you reference are copyrighted to MC and they are selling it as their product...it would likely stand up as original manufacturer even though it is clearly outsourced.

At the end of the day...it'll be up to the lawyers.
 

zork_14

Starting to get Involved
#3
Thanks a lot for your answer @Ninja.

The drawings for the black SHCS you reference are copyrighted to MC and they are selling it as their product...it would likely stand up as original manufacturer even though it is clearly outsourced.
That makes sense, I agree. In this example I should then consider MM as the original manufacturer. I am not supposed to know whether MM is outsourcing its parts and their data sheet is very clear on the compliance (it's probably different for Digikey for example where you can see the original manufacturer, I'll make another post later).

McMaster Carr will play the "we had every reason to believe it"
But is this not simply a widespread card? Or you mean that if they had issued an unambiguous CoC it would be more difficult to play that card?

if anything ever 'hits the fan'
Is it not very unlikely that things would turn bad for simple mechanical components from MM? If I did not have documentation available upon request, then yes it would be an issue. But if I have legally OK documentation (datasheet from original manufacturer), I believe that whoever would go after my parts would first need to prove that the part is not compliant?
 

Ninja

Looking for Reality
Trusted Information Resource
#4
But is this not simply a widespread card?
Totally...and it works...that's why it is used so often.
But if I have legally OK documentation (datasheet from original manufacturer),
You just called two things equal {datasheet = legally OK documentation} ...they may or may not be...and I'm not a lawyer. If it is of enough concern, I would contact counsel experienced in this area.
Is it not very unlikely that things would turn bad for simple mechanical components from MM?
I would think it rather unlikely...but, funny thing is, no one ever calls me to ask what I think in cases like these...gotta make your own call there.
 

Ninja

Looking for Reality
Trusted Information Resource
#5
BTW, I just noticed that these were your first two posts.

Welcome to the Cove! Glad to have you here.
 
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