ROHs compliance requirement

[Kajal]

hello,

We are selling our product to Littelfuse and they are ROHs compliance sellers. they request us to submit certificate of compliance (COC) for our electrical products. Do we need to require Rohs certification before giving them COC ?

NOTE: we do not have ROHS certification

 

[Jen Kirley]

RoHS compliance is usually managed through the procurement processes. Suppliers of the raw materials (particularly that which goes into the final product which would come in contact with the customer) you use can provide certification of analysis (CofA) per lot or batch. I have seen CofA for each shipment, and I have seen contractual arrangements to provide upon request.

With this retained information you can make your own declaration of conformance.

 

[Varsha]

Can anyone say when is RoHS 4 going to release

 

[planB]

As of Apr 2021 - quote from a consultancy (I am not affiliated):

The European Commission was obligated to review RoHS 2 under Article 24 of the directive, and will now present the final report to the European Parliament and European Council. It will be accompanied by any proposals to replace or recast the directive, if deemed necessary. The last recast of the directive occurred in 2013, leading to RoHS 2. A 2019 expansion of RoHS restricted substances is sometimes mistakenly referred to as RoHS 3, despite the fact that it was not a recast.
If proposals for a new directive or regulation are forthcoming, they are likely to be amended several times before the European Parliament and European Council agree on final text. Similar processes in the past have run from 12 to 18 months. When the bodies agree upon text, the recast would be published in the European Commission’s Official Journal complete with a new implementation timeline.

HTH,

 

[Kamila]

Hi all, I struggle a little to apply ROSH logic to my organisation.
We are not a legal manufacturer (design and and distribution is not done by us just by our customers, under their brand).
We are still being ask for the compliance in form of cofc/letter.
To what extent do we have to go to ensure compliance?
Also how is that applicable for example to injection moulding?

any help would be appreciated

 

[planB]

Typically, legal manufacturers of marketed products, that fall under the RoHS directive, seek RoHS compliance for delivered components: in case all components were RoHS compliant, the final product will also be. In case you e.g. injection mold the plug of an electrical cable, the legal manufacturer of the cable might ask you to declare RoHS compliance in a CoC.

HTH,

 

[Tagin]

Hi all, I struggle a little to apply ROSH logic to my organisation.
We are not a legal manufacturer (design and and distribution is not done by us just by our customers, under their brand).
We are still being ask for the compliance in form of cofc/letter.
To what extent do we have to go to ensure compliance?
Also how is that applicable for example to injection moulding?

any help would be appreciated

Ensuring your compliance could be handled a couple of different ways:

• Require RoHS declarations from your suppliers for materials that go into your process and result in the final product.
• If your supplier is, say, a distributor of a chemical, you could go to the manufacturer and get a RoHS declaration from them.
• You could have a chemical analysis performed to determine if the raw materials and/or finished goods are RoHS compliant.

Of course, any of these requires that you have some kind of agreements (or at least CoC) with your suppliers that under no circumstances will they change or substitute other materials, which might cause your product to become non-compliant.

Keep the declarations from your suppliers and any analyses on file. Your customer may also request to see them.

As far as 'to what extent' to go to...this gets into risk:

• What is the risk of trusting your suppliers?
  • Do you think they did a proper upstream review from their suppliers?
  • Do you trust that they won't make changes/substitutions in the future without informing you?
• What are the repercussions (legal, financial, reputation, etc.) if the customer finds that your product you are shipping them suddenly becomes non-compliant?

If you at least have from your suppliers 1) signed RoHS declarations and 2) CoC's for all shipments, then well...I'm not a lawyer but I'd think you'd have evidence that you've done your due diligence.

 

[Kamila]

Thanks everyone for help much appreciated

 

[mehr.qasim]

As per my knowledge, yes you do need RHO’s certification for all devices and sensors as it is a compulsory part of the CE declaration. Without CE and RoHS, corresponding products may no longer be sold in the EU (or countries that follow the EU directive).

 

[i am a QA]

Hi,

Does the supplier has to provide a RoHS certification for each supplier manufacturing lot or can the supplier provide it once and we can use the same certification for all the lots?