Is RoHS issued only by self declaration process?

N

nasimsobh

#1
Hi everyone
We are some ink producer and wanted to get RoHS for our products.
A compny is going to helps us as consultant, doing this and they are emphasizing that there's no auditions necessary for the certificate.
I was not sure about their claim, and I started searching for some audited certificates.

Is there any refrence or any of the members familiar with the topic??
Thnx in Advances.
 
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T

tamale

#2
Nasimsobh,

What you need at most is an independent lab certificate stating the absence of the listed contaminants in your ink.

I am including a letter the substance of witch will be able to guide you.

You will note that ink is not an electrical component.

Beware of hungry consultants!

Tamale
 

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Mikishots

Trusted Information Resource
#3
Nasimsobh,

What you need at most is an independent lab certificate stating the absence of the listed contaminants in your ink.

I am including a letter the substance of witch will be able to guide you.

You will note that ink is not an electrical component.

Beware of hungry consultants!

Tamale
Not sure what you're getting at there - RoHS most certainly does not restrict itself to electrical components; it applies to raw materials, plating, packaging, inks...many varying items.

To address the OP, you would need one of two things; either an independent lab to ascertain if your ink (as a homogenous mixture) contains any of the six banned substances, and if it does, the quantities of said substances OR a certificate of compliance from the manufacturer of the components of your ink. In short, yes, it's self-declared, but you better make sure that either your company or your component suppliers have proof that it was checked and verified, in case your inks are pulled aside for a compliancy exam.
 
R

RobCarl

#4
Agree that RoHS applies to packaging.

I'm a little concerned about the recommendations for lab certificates. There is a time and place for testing, but if a supplier sends me a certificate from a lab and claims to be RoHS compliant based on the single test of one item, I simply cannot accept that.

You need to have a SYSTEM in place to ensure your products will continue to be compliant. Testing is a part of that, but you certainly don't have to test every unit that goes out.

You need a system that evaluates what you suppliers are sending you, usually some sort of risk assessment. We do this through a qualification process. Then you should have (need to have?) some sort of monitoring process to ensure continued compliance. Of course, this implies that you have corrective action and containment processes that you can use to address any violations you uncover during randon sampling.

We only ocassionally send items out to a lab. More frequently, we monitor using an xRF analyzer. These have their limitations (can't tell Hex from non Hex Chrome, or the source of Br, etc., since it's an elemental analyzer), but are good for risk assessment. If anything turns up suscpicious, the supplier needs to provide a reasonable explanation (and evidence if appropriate).

Sorry for a long winded answer, but it's kind of an involved topic. The simple answer is yes, there is only self certification and audits are not required by the letter of the law. All that matters is if the parts are compliant or not when your ink gets checked at customs.

You are not required to "audit", but a strong program (and hence low risk) will include either auditing or monitoring. If you are found to be non-compliant during a customs inspection, it will matter if you performed due diligence or not. It will be difficult to show due diligence if you aren't checking (read auditing/monitoring) periodically to ensure your compliance system is working.

Hope that helps.
 
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