Necessary Compliance Documentation for RoHS and REACH

#1
Our company is in the process of implementing a compliance program for RoHS and REACH. We manufacture a type of computer work station by assembling various smaller articles. We obtain mother board, CPU, chasis, cables, etc from suppliers.

To start, we used a third party testing organization to perform a risk assessment. For "high" risk articles, they recommended us to get a declaration of conformity as well as some kind of material declaration or material test report from the suppliers.

The issue here is that some vendor can give us the declaration of conformity to RoHS and REACH but cannot give us material declaration or material test report due to confidentiality issue or they cant be bother to produce such information.

My question is do we have to strictly follow testing organization's recommendations? Is having just the declaration of conformity sufficient? Is there a standard that I should be following in terms of what documentation is "required" from the suppliers.

Any insight would be greatly appreciated.
 
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Ronen E

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#2
Our company is in the process of implementing a compliance program for RoHS and REACH. We manufacture a type of computer work station by assembling various smaller articles. We obtain mother board, CPU, chasis, cables, etc from suppliers.

To start, we used a third party testing organization to perform a risk assessment. For "high" risk articles, they recommended us to get a declaration of conformity as well as some kind of material declaration or material test report from the suppliers.

The issue here is that some vendor can give us the declaration of conformity to RoHS and REACH but cannot give us material declaration or material test report due to confidentiality issue or they cant be bother to produce such information.

My question is do we have to strictly follow testing organization's recommendations? Is having just the declaration of conformity sufficient? Is there a standard that I should be following in terms of what documentation is "required" from the suppliers.

Any insight would be greatly appreciated.
First of all RoHS and REACH are very different. RoHS is short and sweet. REACH is a regulatory monster.

As far as I understand / know, the most reliable "standards" are the directives themselves. Again, RoHS is straightforward and quite short - just read and follow. REACH, however, is a little nightmare to read and apply directly from the source.
 

QAengineer13

Quite Involved in Discussions
#4
For RoHS the harmonised standard EN 50581 Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances is an good aid to comply with the requirements.
 

blah01

Involved In Discussions
#5
Do items attached to an EEE, such as straps, labels or stickers, nylon filament and so on require evidence of ROHS compliance? Some of our suppliers do not sell their products in the EU and therefore do not have ROHS compliance statements and we are wondering to what extent we need to go to provide compliance on such inert items.
 

normzone

Trusted Information Resource
#6
This will probably only serve to muddy the waters, but here's what I've got.

ROHS is a regulation about waste control. In addition to contractual requirements, there is active enforcement of the ROHS regulations, primarily enforced by customs at the dock, secondarily by laboratories, predominantly regarding consumer goods.
ROHS requires records and is auditable – The supplier provides a Declaration of Compliance (DoC), and any additional records required by the customer

Supplier must maintain a technical file containing ROHS info from component suppliers
The ROHS declaration should be dated, stating when the compliance was asserted and which version of the regulation is referenced. Reference any exemptions re specific components, and specify nature and content of those exceptions

REACH / SVHC is a directive about human exposure – There is no active enforcement, only contractual requirement. REACH is a self assessment and an assertion – it is about the article (read as component) level now, not about the assembly as before.

Primary risks in our line of business is cable jacketing and packaging. Risks even include adhesives in labeling.We must communicate the information to professional users – for the end user, there is no communication requirement. We need to identify our risk areas and develop an overall warning statement. There is no legal wording requirement. As with ROHS, company letterhead and up to date version of the directive is an indicator of validity. The list of substances triggering this requirement is updated periodically, and I'm seeing customer requirements in Ts & Cs that state you will update them if something that is in the product you sold them gets added to that list, even years later.
 
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