How do I know if my product is required be RoHS certified?

Marcel DS

Starting to get Involved
#1
Dear Gentlemen,

I have a product for Automotive Industry which was questioned for RoHS, I know many Directives in EU are also harmonised with RoHS, so
following the RoHS guidelines for product composition is vital, however, how do I know if my component (Electronic assembly) needs a RoHS Certificate?

Thank you,

Best Regards

Marcel
 
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Jen Kirley

Quality and Auditing Expert
Staff member
Admin
#2
Good day Marcel, welcome to The Cove!

The easiest way to learn if your product is required to conform to RoHS is to ask your customer. If you have been provided with drawings/specifications or access to them, the requirement would likely be within them.

If you don't have access to these specifications or they do not provide this information, ask your Customer Service person to give you contact information for your customer(s) so you can inquire based on part numbers.

I hope this helps!
 

Marcel DS

Starting to get Involved
#3
Hi Jens, thank for the warm welcome.

In fact, our customer is aware of the RoHS, (but it seems they leave that to us) but as we assemble components and transform it into modular parts, we can have our suppliers (electronic components) to have RoHS certificates. Through the just google: mdsystem.com/imdsnt/startpage/index.jsp IMDS database it is possible to have a lot of info on materials used for Automotive industry, if we have suppliers who are RoHS certified, we are ok.

However, if we have any doubt we must test it, invidually as importers of products in Europe, our company is also responsible for not using the materials described in the RoHS catalogue. So to avoid liability, certificates must be documented and in case of doubt, we may require a test. That is what I learned from other Certification companies.

The good thing is that we really do not need a test or a certificate to comply, if all our assembly products and materials carry a RoHS certificate. However, if there are some materials, components, we are not sure, it would be better to change supplier.

That is what I found on it, but thank you for the input it helped to confirm what I found.
 

Jen Kirley

Quality and Auditing Expert
Staff member
Admin
#4
Good day Marcel,

The best way to manage this is through procurement of RoHS conforming materials with which to accomplish your assembly processes as per the requirements of your customers. Many of my suppliers provide documents declaring this due diligence has taken place. In the potential event of an audit, I recommend you retain RoHS certifications for your raw materials and to be prepared to show how those materials came to be included in your assemblies. Traceability is important.

I hope this helps!
 

Alex73

Involved In Discussions
#5
Hi Jens, thank for the warm welcome.

Through the just google: mdsystem.com/imdsnt/startpage/index.jsp IMDS database it is possible to have a lot of info on materials used for Automotive industry, if we have suppliers who are RoHS certified, we are ok.
Hi Marcel,

The IMDS database is related with the automotive EU ELV directive.

On the other hand, RoHS (2011/65/EU) applies to electrical and electronic equipment (EEE). See annex I of the directive to know which categories of EEE are covered. However, in my opinion, if you do not have feedback from your customer then the boundary is not clear. Take as an example a CD player (the hardware), if it is been used in a Walkman then RoHS applies but if it had been used in a car stereo then ELV applies. Thus, it is always a good idea to know your final product will be used.

As you mentioned, IMDS can provide a lot of information regarding the material composition. But please be aware that the IMDS (i.e. ELV) exemptions are different from the RoHS exemptions. An example of that is Cadmium that is allowed by RoHS but cannot be used any more on the automotive industry. On such situation either you have to contact the supplier to know the correct RoHS exemption or you take the responsibility to select.

For more details please check:
Waste - Environment - European Commission
Electrical and electronic waste - Environment - European Commission

Some customers may request RoHS because of the phthalates (mainly the DEHP that is a REACH SVHC).


Hope this can help you.

Alex.
 

Marcel DS

Starting to get Involved
#6
Good day Marcel,

The best way to manage this is through procurement of RoHS conforming materials with which to accomplish your assembly processes as per the requirements of your customers. Many of my suppliers provide documents declaring this due diligence has taken place. In the potential event of an audit, I recommend you retain RoHS certifications for your raw materials and to be prepared to show how those materials came to be included in your assemblies. Traceability is important.

I hope this helps!

Pretty good to know, that is one of the ways I was thinking about it, now I have one confirmation about it.
 

Marcel DS

Starting to get Involved
#7
Hi Marcel,

The IMDS database is related with the automotive EU ELV directive.

On the other hand, RoHS (2011/65/EU) applies to electrical and electronic equipment (EEE). See annex I of the directive to know which categories of EEE are covered. However, in my opinion, if you do not have feedback from your customer then the boundary is not clear. Take as an example a CD player (the hardware), if it is been used in a Walkman then RoHS applies but if it had been used in a car stereo then ELV applies. Thus, it is always a good idea to know your final product will be used.

As you mentioned, IMDS can provide a lot of information regarding the material composition. But please be aware that the IMDS (i.e. ELV) exemptions are different from the RoHS exemptions. An example of that is Cadmium that is allowed by RoHS but cannot be used any more on the automotive industry. On such situation either you have to contact the supplier to know the correct RoHS exemption or you take the responsibility to select.

For more details please check:


Some customers may request RoHS because of the phthalates (mainly the DEHP that is a REACH SVHC).


Hope this can help you.

Alex.

Thanks a lot, listing about the exceptions was really nice. I will check deeper into RoHS and ELV Direktive, in my case here we manufacure power components for E-vehicles. I have here a book that says it would apply to any EEE (Electrical and Electronic Equipment) not exceeding 1000 Vac and 1500 Vdc. In Automotive, not all CE directives are applied, because the automotive type approval is controlled by ECE norms, which are some in the DNA of CE directives. But I will go deeper into the differentes between ELV and RoHS. Thanks a lot for the valueable input.
 
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