RoHS Compliance - Steel - Customer wants additional samples tested

Ajit Basrur

Staff member
Admin
#21
Hello Quality partners, need your wise advice and opinion:

Now we have a customer that still wants our company to send samples of our steel for testing to a laboratory for further analysis which is very expensive. I believe this is redundand and not needed because our steel suppliers are already ensuring to us with their COC's about RoHS compliance, any issues of nonconpliance could be traced back to the steel suppliers.

Our customers are really pushing for this extra testing, I am trying to find a persuasive argument to convince them to change their mind and accept our COC's. What are your opinions?
There are 2 issues here - one is on RoHS and you are completely compliant and there are no issues attached.

However, the additional Customer Specific requiremements also need to be absent. There is a standard called as IECQ 080000 addressing "Hazardous Substance Process Management System Requirements (HSPM)" which combines RoHS plus customer dictated requirements.

This std can be obtained from IEC Webstore. I am attaching a very good presentation for your info.
 

Attachments

Elsmar Forum Sponsor
C

chergh - 2008

#22
I am little curious about methods such as ICP MS and XRF are being required.

First thing is I doubt ICPMS can tell what the oxidation state of chromium in a sample is. From what I remember of my training as an analytical chemist a method such as AES (Auger Electron Spectroscopy) or a more traditional wet chemistry method, reacting the compound and then using a colourimetric method, would need to be used.

XRF has always been in my experience at best a semi-quantitative technique and certainly not one to be used where an accurate measurement is required.

These methods also have very low limits of detection (certainly in the parts per billion range) where as RoHS seems to be using percentage impurity which even when as low as 0.01% is still equivalent to 100 ppm which can be easily, cheaply and accuratley measured using methods such as flame AAS (Atomic Absorption Spectroscopy) or AES (Atomic Emission Spectroscopy).

Are these really the requirements?
 

ScottK

Not out of the crisis
Staff member
Super Moderator
#23
Re: RoHS compliance

Medical devices are exempt from the RoHS requirements right now. So, they shouldn't have much concern.

even so - some are asking for it.
And other customers are not exempt and are happy with what we've sent them as long as the material certs from our suppliers are in order.

of course it makes no financial sense whatsoever for a customer to require us to provide our own testing because our parts are, in general, not expensive.
 
M

MikeW46

#24
This is not an uncommon request. In cases where a customer considers the material to be of high risk of non-compliance, by their standards, they feel that they need to show they have done due diligence on their data requests. What I suggest is that you provide XRF qualitative data to show a screening of the data for the absence of the substances. This is much less costly compared to a lab analysis and should meet their verification needs.
 
J

juliov

#25
Mike, I believe our customer is going the extra mile to ensure their compliance to RoHS. Can you expand a bit about the XRF qualitative data screening, would this really comply to RoHS? interesting.
Thanks,
 
M

MikeW46

#26
The approach using XRF is not to provide a full analysis, but to confirm the resonability of the lab data that was provided by your metal supplier. There is no real value added in repeating lab tests unless there is a reason for concern at your end. An XRF scan to determine the presence of a substance, or confirm that a substance is there provides a proof of "due diligence" (see http://www.rohs.gov.uk/content.aspx?id=7 ). the verification scan with XRF is the suggested approach to have taken all reasonable steps or precautions and have exercised all due diligence to avoid committing the offence. I have an explanation of due diligence posted at http://www.rsjtechnical.com/WhatisDueDiligence.htm . Proving you have verified the data should be what they are looking for, not full retest.

With the reported numbers of incorrect submission data possibly still being as high as 20-30%, it is not surprising that this is being requested. Depending on who the material is processed at your facility, you may want to do the scan post processing to verify that no contaminents were introduced during processing.
Hope this helps.
 
J

juliov

#27
Absolutely. Thanks Mike for the advice. I'll review the two links you provide in order to get more info.
 
J

JHagani

#28
Re: RoHS compliance

In general, CoC's are worthless in terms of providing objective evidence of anything. Suppose your company wanted to become ISO-registered. Do you suppose that you could send the registrar a Certificate of Compliance and thus avoid an actual audit?


QUOTE]

I agree with Jim completely.
CoC's can't provide objective evidence. IMHO even Chemical and Physical certs are not enough.
What we have been doing: Collect 2 random coupons from each material supplier per year, send to our independant lab for testing. This works as part of our auditing our supplier, and as objective evidence.
 

harry

Super Moderator
#29
The approach using XRF is not to provide a full analysis, but to confirm the resonability of the lab data that was provided by your metal supplier. There is no real value added in repeating lab tests unless there is a reason for concern at your end. An XRF scan to determine the presence of a substance, or confirm that a substance is there provides a proof of "due diligence" (see http://www.rohs.gov.uk/content.aspx?id=7 ). the verification scan with XRF is the suggested approach to have taken all reasonable steps or precautions and have exercised all due diligence to avoid committing the offence. I have an explanation of due diligence posted at http://www.rsjtechnical.com/WhatisDueDiligence.htm . Proving you have verified the data should be what they are looking for, not full retest.
Mike, thanks for your input. That kind of wrap up the whole discussion on this topic. With regards to methods of analysis, many others such as AAS, ICP-OES, ICP-AES are used also. Check with your client (especially Sony) if they have any required/preferred methods or even labs.

Regards.
 
M

MikeW46

#30
Harry,
I'm glad you pointed out that XRF isn't the only verification approach. Any that your customer accepts will work. The key, especially for European RoHS compliance is that, like all areas of quality, it has to be part of a an ongoing process. When REACH hits us, those processes will be even more critical.
 
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
J ROHS compliance for MRO (Maintenance, Repair & Overhaul) Items RoHS, REACH, ELV, IMDS and Restricted Substances 11
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
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