leftoverture

Involved In Discussions
#1
Hello All,
Just trying to get a little feedback here. We are a small, family-owned contract manufacturer in the plastics industry. I am new to the realm of compliance. Our customers are asking more and more for us to certify compliance to the various regulations such as REACH, ROHS, prop 65, etc. It is my understanding that the REACH SVHC list is updated about every 6 months and our customers are asking us to resubmit compliance every time the list is updated. Being a small company such as we are, we do not have a compliance department or even a compliance officer so all the added labor to update the documentation is rather burdensome. Being we are a job shop, we use only the materials our customers specify, we have no design control at all, so I am uncertain why we should be expected to provide the compliance documents. Shouldn't our customers establish that the material is compliant with REACH, ROHS, prop 65, or what have you prior to specifying that we use it?
I would appreciate any feedback that can help us understand this better.
Thanks!
 
#2
They should but they don't. This all a "stuff rolls down hill" requirement. If you using molding resins, you can check with manufacturer/distributor to get their reach info and pass it along to your customer. We created a series form letters for each reg. Good luck.
 

leftoverture

Involved In Discussions
#3
They should but they don't. This all a "stuff rolls down hill" requirement. If you using molding resins, you can check with manufacturer/distributor to get their reach info and pass it along to your customer. We created a series form letters for each reg. Good luck.
Yes, we have form letters also. Our customers will not accept the documents from the material suppliers, always has to be on our letterhead. And some have their own forms they want us to fill out, one for each part number (we have hundreds). Are you in plastics also? Any experience with FMD (full material disclosures) from your resin suppliers?
 

somashekar

Staff member
Super Moderator
#5
Hello All,
Just trying to get a little feedback here. We are a small, family-owned contract manufacturer in the plastics industry. I am new to the realm of compliance. Our customers are asking more and more for us to certify compliance to the various regulations such as REACH, ROHS, prop 65, etc. It is my understanding that the REACH SVHC list is updated about every 6 months and our customers are asking us to resubmit compliance every time the list is updated. Being a small company such as we are, we do not have a compliance department or even a compliance officer so all the added labor to update the documentation is rather burdensome. Being we are a job shop, we use only the materials our customers specify, we have no design control at all, so I am uncertain why we should be expected to provide the compliance documents. Shouldn't our customers establish that the material is compliant with REACH, ROHS, prop 65, or what have you prior to specifying that we use it?
I would appreciate any feedback that can help us understand this better.
Thanks!
What I can suggest to you is to ask your customer (Hoping he is a big corporate) to open a customer account and you then open a supplier account linking to this customer and submit all declarations in <www.bomcheck.net>
Based on your turnover, I believe you do not have to pay any annual renewal fee for your supplier account. Kindly discuss this and check it out with your customer.
Alternately, go through the information in <www.bomcheck.net> to appraise yourself about how a declaration can be made by yourself with the information available.
NOTE: I am not associated with <www.bomcheck.net> but as a supplier I am aware and find this helpful to understand and provide declaration.
 

leftoverture

Involved In Discussions
#6
BOMCheck seems like a nice concept, I have been reading about it but not sure if any of our customers use it or not. Most of our suppliers have thus far refused to provide FMD because they feel their formulations are proprietary.
 

Ninja

Looking for Reality
Trusted
#7
What customers want, and what they will get are two different things
Golfman listed two options...here's a third...
1. What they want (ask for)
2. What they are willing to pay for (per piece or per submission charge)
3. What you are willing to supply for free (Golfman's "What they get")

It is reasonable to open the discussion regarding the costs of frequent re-submission. It is less reasonable (though possible) to offer an ultimatum.

We threw in the first submission for free, if the customer wanted a re-submission to an SVHC update, we looked at the size of their business with us and then decided whether or not to charge them (we usually did)...preferably per piece ... each time the customer asks for more is a new opportunity to negotiate price.
 

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