Difficulties getting RoHS/REACH for cheap parts

#1
I'm trying to get RoHS and REACH declarations on some common off the shelf parts, like shirt clips and plated springs. The best responses I've gotten are 10 year old test reports on the parts in question. We need these declarations so that we can declare our product (which uses these parts) compliant.

Has anyone dealt with this problem? I presume our only option is to send the parts for lab testing.

Is there any room for a risk based approach, ie "This part is very likely 303 stainless, and doesn't need to be tested for us to feel ok declaring it compliant."
 
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#2
I presume our only option is to send the parts for lab testing.
That's what we determined...and did so.
CYA is one thing...and having the 10yr old statement is likely enough for that....risk, but low risk...you asked for it multiple times and got a thing...that covers you receiving it.

Is there any room for a risk based approach
You declaring it is far different (legally) than you accepting that someone else you've never seen declares it.
Yes, there is room for a risk based approach...and your lawyer should be the one who judges that risk...IMO.

We sent it for testing (sampled, certainly not every piece) before we were willing to write the declaration (based on lab results, not some miscellaneous piece of paper of unknown validity).
 
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