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REACH and ROHS compliance for hundreds of parts made over 25 years

R. Webb

Involved In Discussions
I just received a request for a declarative statement regarding REACH and ROHS compliance for hundreds of parts that have made for a fortune 500 company over the past 25 years. Some of these parts have not been made since 2005 and before and some predate our electronic records so I have no records of them. Also some vendors are no longer in business. As I work for a small company we really do not have the staff or expertise to research all of this. My immediate reaction is to tell them if they designed the part(s) to be compliant then they are compliant as we made the parts to print. However that is not too customer friendly and have been advised against it. I do not have a problem with parts that have been made in the last few years and any active part numbers but going back as far as the last century seems a little much to ask.

Has anyone else encountered this and if so any ideas on how to handle it?


Quite Involved in Discussions
Tell them the truth. Consider the shelf life of the material and say you can only provide the requested information for parts made the last 5 years.
I had to do that. Customer hadn't bought the parts since 2005, still had some in Inventory and we said, sorry cannot do.


Involved In Discussions
Another angle to limit the amount of work: Check what your customer specified for record retention and any information you sent the customer about how long you retain records. Anything beyond the record retention time is off the table.
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