ROHS compliance for MRO (Maintenance, Repair & Overhaul) Items

J

Joe Luis

#1
part of my job is to validate ROHS complaince for our products but I am having trouble on the MRO items - screws, nuts, washers, and the supplier, McMaster, specifically, will not give any ROHS compliance data on the items they sold. Do you guys have similar experience with them and how do you solve this problem? I am also been assigned to handle REACH now so need help badly.
 
Elsmar Forum Sponsor

harry

Super Moderator
#2
part of my job is to validate ROHS complaince for our products but I am having trouble on the MRO items - screws, nuts, washers, and the supplier, McMaster, specifically, will not give any ROHS compliance data on the items they sold. Do you guys have similar experience with them and how do you solve this problem? I am also been assigned to handle REACH now so need help badly.
As I suspected, the MRO segment is actually exempted from RoHS. But it was then and I don't know the situation now. The rationale for the exemption is that time will take care of itself - meaning manufacturers supplying the OEMs will eventually have one type of product (one type of process), the RoHS compliance type.

You may want to read the article in this link.
 

Kales Veggie

People: The Vital Few
#3
part of my job is to validate ROHS complaince for our products but I am having trouble on the MRO items - screws, nuts, washers, and the supplier, McMaster, specifically, will not give any ROHS compliance data on the items they sold. Do you guys have similar experience with them and how do you solve this problem? I am also been assigned to handle REACH now so need help badly.
Can you explain why MRO items have to be RoHS compliant for your product?

REACH is a EU regulation that will have a big effect on business. Do you export your products to the EU (today or in the future)?

Your company has to develop a REACH policy, educate your company cascade that the the supply base. At a minimum sales/marketing, engineering and purchasing has to be aware of the restricted material requirements.

This is not something you should/can do on your own.
 
J

Joe Luis

#4
the items I referred to are not at the maintenance or repair or operational - I am actually referring to the screws, nuts, bolts and washers used in the bill of materials. As our customers demand for RoHS complaint on our products, I need to make sure all items used in the BOM are RoHS complaint, which include the screws, nuts, bolts and washers - most of them come as SST 304 but with different plating options that only the suppliers know - they may or may not contain the hexavalent-chromium. That is why I kept requesting the RoHS compliance status from our supplier, McMaster, but can never got any info from them about the RoHS compliance status on such items. Can you share your exeperience in handling situation like this?

Joe
 

qu1nn

Involved In Discussions
#5
For items that I couldnt get a RoHS compliancy statement I would have tested at a company such as TUV Rheinland where they would be able to do additional tests to determine compliancy (ie grind up & chemical tests). This information stays on file and can be used as objective evidence.

hth
qu1nn
 

Kimmy

Involved In Discussions
#6
MRO exemption? There is an exemption which allows up to 3500 ppm (.35%) of lead in the mild steel alloys used to machine nuts and bolts however, most nuts and bolts are chrome plated and will contain hexavalent chrome. I am not aware of any exemption for hex chrome contained in plating.

I don’t think outside testing would work for suppliers like McMaster because they buy their stock from many different manufacturers – whoever is cheaper at the time they need to restock. You would have to test every order you receive in order to certify.

You might want to investigate purchasing your items from a smaller company that sells only fasteners. I think they would have better luck in obtaining RoHS information from their suppliers.
 
L

lday38

#8
ROHS and Intertek standards?

I am new to the small kitchen appliance manufacturing. My company gets most of the parts from China but there is some parts coming from US. Our blenders are manufactured in the united States. I sit in meeting where they discuss the above organizations. I want to learn more about the requirements. UL does have them listed but intertek doesn't seem too but I may be missing the boat.I am used to ISO standards. Certifications from our suppliers is what is on my mind at the moment.
 

Kales Veggie

People: The Vital Few
#9
Re: ROHS and Intertek standards?

I am new to the small kitchen appliance manufacturing. My company gets most of the parts from China but there is some parts coming from US. Our blenders are manufactured in the united States. I sit in meeting where they discuss the above organizations. I want to learn more about the requirements. UL does have them listed but intertek doesn't seem too but I may be missing the boat.I am used to ISO standards. Certifications from our suppliers is what is on my mind at the moment.
If these requirements apply to you, depends where you buy, where your products are sold or are exported, what your products contain and what industry?

As a buyer of product, you have to specify in your purchase order and specification, what regulations the product and supplier has to comply with. Your company has to trust the supplier and get certification (in form of a certificate or chemical analysis of the product) with first shipment or every shipment.

ROHS = applies to electrical and electronic equipment imported into the EU
ELV = applies to vehicles sold in EU that weigh over 2.5 tonnes in EU
WEEE = applies to disposal of electrical and electronic equipment in EU
REACH = applies to almost all products imported and manufactured in EU

Other countries (including Canada) and California are working on regulation to control hazardous and toxic substances in product.

I am not sure if I answered your question. Please elaborate on what information you are looking for.
 
L

lday38

#10
Actual standard with rules

This was informative. But I am looking for the actual requirement in writing, I would suppose they would have something like ISO 9001. I know UL has some standrads online.
Intertek describes testing they have and their ETL symbol but I dont see actual standards on their web site. UL does have standards.
We import product and some parts from China. This may be motors, electric switches or a whole assembly.
We also make one product in Pa. Parts, plastic primarliy are made in th United States.
Certifications are being filed for a UL audit. They come with every shipment. Some ship product every other week while others is once a year. The certs dont say much , and most are on the same PO.
I want to know the exact requirements from these bodies and our customers.
The paper should mean something and be traceable to the product but that is often not the case. Lin
 
Thread starter Similar threads Forum Replies Date
T Training recommendations? Bringing our RoHS and REACH compliance efforts in-house REACH and RoHS Conversations 2
R Certificate of compliance to RoHS/REACH/WEEE - any such animal? REACH and RoHS Conversations 18
Ed Panek CE REP questions about our devices ROHS compliance REACH and RoHS Conversations 1
R REACH and ROHS compliance for hundreds of parts made over 25 years REACH and RoHS Conversations 3
T CE Marking & Compliance to MDD, EMC, RoHS, and GPSD REACH and RoHS Conversations 4
D How do I show compliance to RoHS, REACH and Conflict Minerals? REACH and RoHS Conversations 6
P Necessary Compliance Documentation for RoHS and REACH REACH and RoHS Conversations 5
M RoHS Directive - Supplier Compliance - Declaration of Conformance CE Marking (Conformité Européene) / CB Scheme 12
dubrizo Who handles Your Reach, RoHS, 3TG Compliance RoHS, REACH, ELV, IMDS and Restricted Substances 9
smryan Compliance Officer Outsourcing? RoHS, REACH, ELV, GADSL, IECSC Other ISO and International Standards and European Regulations 5
A RoHS compliance - Our market is non EU countries only ISO 13485:2016 - Medical Device Quality Management Systems 4
N RoHS Compliance requirement for Hexavalent Chromium RoHS, REACH, ELV, IMDS and Restricted Substances 6
R RoHS Compliance Problem with One Component RoHS, REACH, ELV, IMDS and Restricted Substances 5
L What needs to be done to prove compliance with RoHS and WEEE EU Medical Device Regulations 5
A Start Compliance to RoHS, SCHV and REACH RoHS, REACH, ELV, IMDS and Restricted Substances 10
S What needs to be done to demonstrate RoHS compliance for Medical Devices? RoHS, REACH, ELV, IMDS and Restricted Substances 6
J RoHS/REACH Compliance Tools and PLM Integration RoHS, REACH, ELV, IMDS and Restricted Substances 14
C Legacy Medical Devices -- RoHS compliance in 2014 or 2019? RoHS, REACH, ELV, IMDS and Restricted Substances 5
D IVDD RoHS Directive Compliance to 2011/65/EU RoHS, REACH, ELV, IMDS and Restricted Substances 4
A Are RoHS compliance certs sufficient to qualify material? RoHS, REACH, ELV, IMDS and Restricted Substances 6
B RoHS Compliance for a Medical Device Manufacturer RoHS, REACH, ELV, IMDS and Restricted Substances 12
O Sample RoHS Compliance Procedure for plastic injection molding needed RoHS, REACH, ELV, IMDS and Restricted Substances 2
M Experience with IPC 1752 compliance? Manage and report ROHS information RoHS, REACH, ELV, IMDS and Restricted Substances 4
A Certification of Raw Materials for RoHs Compliance RoHS, REACH, ELV, IMDS and Restricted Substances 3
E XRF vs. Spark Test for RoHS Compliance Verification RoHS, REACH, ELV, IMDS and Restricted Substances 24
J RoHS Compliance - Steel - Customer wants additional samples tested RoHS, REACH, ELV, IMDS and Restricted Substances 32
I Method of Identifying and Segregating of RoHS Compliance Material RoHS, REACH, ELV, IMDS and Restricted Substances 7
M Find updates to REACH and Rohs regulations REACH and RoHS Conversations 1
I When is necessary to have RoHS declaration on non-electrical parts? REACH and RoHS Conversations 1
G RoHS Procedure REACH and RoHS Conversations 2
Marcel DS How do I know if my product is required be RoHS certified? REACH and RoHS Conversations 6
C Difficulties getting RoHS/REACH for cheap parts RoHS, REACH, ELV, IMDS and Restricted Substances 1
M Informational RoHS Standard - EN 63000:2018 to replace EN 50581:2012 Medical Device and FDA Regulations and Standards News 11
R ROHS Exemption Declarations REACH and RoHS Conversations 5
M ROHS : Applicability for AIMDs RoHS, REACH, ELV, IMDS and Restricted Substances 2
J Where can I find the latest update to Reach and ROHS? REACH and RoHS Conversations 9
padraick63 REACH and ROHS Requirement for a Molded Part REACH and RoHS Conversations 1
T China ROHS exemptions - Are there any exemptions for ROHS 2 China? REACH and RoHS Conversations 0
D The Status of ROHS for Medical Devices - April 2019 REACH and RoHS Conversations 3
S Prop 65 and RoHS statement REACH and RoHS Conversations 6
J What my companies RoHS declaration should say 2011/65/EU, 2015/863, or 2017/2102 REACH and RoHS Conversations 3
bio_subbu EU Publishes New DIRECTIVE (EU) 2017/2102 AMENDING 2011/65/EU ON ROHS-2 REACH and RoHS Conversations 0
J RoHS, WEEE and REACH Consulting Expertise Needed REACH and RoHS Conversations 4
Q Guidance regarding Legally Refurbishing a Non-RoHS Instrument in the EU REACH and RoHS Conversations 1
M ROHS & REACH in TEFLON Material - NABL Testing Laboratories REACH and RoHS Conversations 1
S Sell a Non-RoHS device, manufactured before RoHs regulations became effective? EU Medical Device Regulations 2
Q EU ROHS and GUI Usability Trial Requirements EU Medical Device Regulations 10
B RoHS Directive 2014/5/EU Leaded Solder Exemption RoHS, REACH, ELV, IMDS and Restricted Substances 2
bio_subbu Official Journal of EU published two new RoHS Exemptions EU Medical Device Regulations 1
D Will A Few Failed Solder Joints Make Me RoHS Non Compliant? RoHS, REACH, ELV, IMDS and Restricted Substances 9

Similar threads

Top Bottom