RoHS Directive - Supplier Compliance - Declaration of Conformance

M

MJW66

#1
I was wondering if anyone else is having difficulties with their suppliers attesting to RoHS compliance on a lot by lot basis. Some suppliers have informed us that they will not do this, but will offer a declaration of conformance on an annual basis. I know that this is weak, but would it be acceptable? We could add some language regarding any changes that might occur during the year, but it is still not as good as lot by lot certification. All of our products have CE marking through self-certification. Thoughts?
 
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Ninja

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#2
Re: RoHS Directive - Supplier conformance

RoHS has requirements that often (though not always) involve additional testing (such as ppm Pb content). Regardless, it is another piece of paper that has cost in itself to fill out, and risk associated with attestation.

Annual testing has one cost. Testing every lot has more cost.
You have asked for lot by lot...what $$ have you offered in exchange for the additional costs you have asked them to bear?

If you asked them to spend money, and offered them nothing in exchange, it is not surprising that the answer might be "No".
If you ask enough people, you may also get the answer "Your new product price will be $____"

Demanding that vendors do what they promised is one thing (and quite reasonable)
Demanding/requesting that they do more is, well, more...
 

normzone

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#3
Re: RoHS Directive - Supplier conformance

I've little to add at this time, but I am following this thread. Customer requirements are driving increased regulatory compliance, and this means additional work. The money has to come from somewhere.
 
M

MJW66

#4
Re: RoHS Directive - Supplier conformance

Hello Ninja:

The RoHS requirement was upfront as part of the original purchase order. I can understand if it was an "add-on", but quite simply, it was not. However, even though it was upfront, it doesn't help us if they will not comply with a DoC with every shipment. I posted this to see if others have experienced the same and what their minimum objective form of compliance was with respect to their suppliers. I am familiar with the physical testing that we can do.
 

Ninja

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#5
Re: RoHS Directive - Supplier conformance

The RoHS requirement was upfront as part of the original purchase order. I can understand if it was an "add-on", but quite simply, it was not. However, even though it was upfront, it doesn't help us if they will not comply with a DoC with every shipment. I posted this to see if others have experienced the same and what their minimum objective form of compliance was with respect to their suppliers. I am familiar with the physical testing that we can do.
I don't mean to play semantics...but in this case it makes a large difference...

"The RoHS requirement was upfront as part of the original purchase order."
Which RoHS requirement?
- To comply
- To test and provide DoC with every shipment
A lot of $$ difference between these.
{And being part of the original purchase order is rather different than it being mutually agreed...}

I can comply with the speed limit any time I drive.
Proving to you that I do every time I drive is a whole lot more work.

Why not simply ask your customer what they do to ensure compliance?
That seems a more productive starting place than trying to figure out what is "reasonable to others".

You can then base your handling of the situation on that.

20/20 hindsight...having them define the compliance method and verification frequency might have been best worked out during the negotiation. Keep it in mind for the next vendor.

There's a thread on here somewhere about things that were part of purchase order terms...
 
M

MJW66

#7
Re: RoHS Directive - Supplier conformance

To be honest, I'm not sure how else to describe this. We asked for components that are RoHS compliant and that we receive a CoC stating this with every shipment. Some suppliers will not comply. We did not ask for testing. I thought this was clear in my first post, but maybe it was not.
 

Ninja

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#8
Re: RoHS Directive - Supplier conformance

We asked for components that are RoHS compliant and that we receive a CoC stating this with every shipment. Some suppliers will not comply.
Again, it is in the sematics:

You asked for it. Understood.
Did they agree to do it? It seems not.

Giving an RoHS conformance statement lot by lot (or is it shipment by shipment?) is not like giving a boilerplate CoA lot by lot reporting data tested already...it is more work and likely more expense for them.

You asked for more work from them.
They said "no".
The next logical step is to see what the issue is.
If it is money (my guess), then the next step is to see :

1. what it is that you actually NEED.
2. how much it costs to get that
3. negotiate who pays what part of that cost.

FWIW, in the same position as your vendor I have quoted the additional cost of complying with your request...it wasn't cheap...in one case it tripled the cost of the goods.
Funny how that customer suddenly realized that they didn't really "NEED" it.
 
M

MJW66

#9
Re: RoHS Directive - Supplier conformance

They accepted the purchase order and sent in the parts. That is not saying "no", that is not complying. An upfront additional cost on their end should have been communicated back to us before they accepted the P.O. That's the way it should work. I appreciate all of your feedback, but it doesn't answer my original question as to what others do in this situation. Thanks.
 

Ninja

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#10
Re: RoHS Directive - Supplier conformance

Fair enough.

Here's what I do, for this any many other situations like it.
...see what the issue is.
If it is money ..., then the next step is to see :

1. what it is that I actually NEED.
2. how much it costs to get that
3. negotiate who pays what part of that cost.
Let's see what others suggest.
 
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