How do I show compliance to RoHS, REACH and Conflict Minerals?

#1
Hi Guys,

We are CNC manufacturing company, and we need to define our RoHS, REACH and CM overseeing.


Have you made any progress, do you have some summary on needed activities to solve RoHS compliant status inside your company?

I was thinking to build a list in Excel with all suppliers, contact them to supply us with their RoHS certificate.

Then I would mark green all of them that comply. Those who does not, I would mark them red and all material sent by them would be also red...I guss


Do you track only your suppliers or you need to define certificate for each product?

BR. Denis R.
 
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Ronen E

Problem Solver
Staff member
Moderator
#3
Hi Guys,

We are CNC manufacturing company, and we need to define our RoHS, REACH and CM overseeing.


Have you made any progress, do you have some summary on needed activities to solve RoHS compliant status inside your company?

I was thinking to build a list in Excel with all suppliers, contact them to supply us with their RoHS certificate.

Then I would mark green all of them that comply. Those who does not, I would mark them red and all material sent by them would be also red...I guss


Do you track only your suppliers or you need to define certificate for each product?

BR. Denis R.
Before you start doing a lot of work you need to really understand what regulations apply to your company. Not just top-level (“RoHS”, “REACH”) but in detail - which sections apply to you, if any. REACH has many levels, and I’m not even sure RoHS applies to you.

The regulations are available online and there’s also a lot of free guidance online, or you can contact a professional.

Disclosure: I do this kind of consultation, and there are many others around.
 

somashekar

Staff member
Super Moderator
#4
Hi Denis ...
Are you a part of the supply chain to a major. Are you tier 1 by chance ?
Compliance to these are mostly driven from the major corporate, and you have to provide declarations towards these requirements.
As Ronan mentioned, there is a lot of free guidance online, however the one that best suits you must be investigated for its correctness in meeting the requirement.
<www.bomcheck.net> is a easy tool for declarations as well as informations about these. It must be however driven by your principle customer (The reason why I asked about your supply chain and tier status)
Do see and find out more how Bomcheck can help you...
[PS: I am not associated with Bomcheck.net. I am an user and happy with this site being a tier 1 medical supplier]
 

mihir.bajekal

Starting to get Involved
#5
Hi Guys,

We were recently audited for IATF 16949, in which RoHS compliance was checked by the auditor for an aluminium alloy that we use in our manufacturing process.

We had a declaration from our vendor regarding the RoHS compliance and also a test certificate from him showing ONLY the composition of the material.

However, the auditor commented that since there was no backup data from the supplier regarding the usage of banned substances, the declaration was not acceptable.

We submit similar declarations to our customers whenever they require RoHS proof and it is always accepted. What do you guys think about the comments made by the auditor? Are they valid? Do I need to get a certificate of RoHS from an NABL accredited third party laboratory?

Regards
Mihir
 

somashekar

Staff member
Super Moderator
#6
Hi Guys,

We were recently audited for IATF 16949, in which RoHS compliance was checked by the auditor for an aluminium alloy that we use in our manufacturing process.

We had a declaration from our vendor regarding the RoHS compliance and also a test certificate from him showing ONLY the composition of the material.

However, the auditor commented that since there was no backup data from the supplier regarding the usage of banned substances, the declaration was not acceptable.

We submit similar declarations to our customers whenever they require RoHS proof and it is always accepted. What do you guys think about the comments made by the auditor? Are they valid? Do I need to get a certificate of RoHS from an NABL accredited third party laboratory?

Regards
Mihir
If your 16949 auditor gives anything in writing about this, please do share here. Otherwise I believe you are on track about this.
 

Golfman25

Trusted Information Resource
#7
Hi Guys,

We were recently audited for IATF 16949, in which RoHS compliance was checked by the auditor for an aluminium alloy that we use in our manufacturing process.

We had a declaration from our vendor regarding the RoHS compliance and also a test certificate from him showing ONLY the composition of the material.

However, the auditor commented that since there was no backup data from the supplier regarding the usage of banned substances, the declaration was not acceptable.

We submit similar declarations to our customers whenever they require RoHS proof and it is always accepted. What do you guys think about the comments made by the auditor? Are they valid? Do I need to get a certificate of RoHS from an NABL accredited third party laboratory?

Regards
Mihir
This is why auditors shouldn't audit content of documents. From our experience he is completely wrong. RoHS is a content requirement, even thought they use the term "used." Certifications I am familiar with all say something to the effect that the banned substance doesn't meet the threshold level in the product at issue.

Did he give you a nonconformance or just make a silly comment?
 
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