ROHS Exemption Declarations

Ralba

Involved In Discussions
#1
Hello all,

I am a relative newbie to the field of electronics. A customer has asked us for a RoHS compliance form for a we have made for them, and we issued a standard one with no exemptions claimed. All parts used on this product are from the BoM issued by our customer. When the customer does not specifically request leaded solder, we tend to use unleaded.

I was under the impression that the declarations of exemptions were for the whole product you are manufacturing. However, this customer has asked us if we really have no exemptions, because one of the components used in the final assembly (a small, galvanized spacer) is exempt under 6(a)-I, machined metal leaded content.

So please help me understand when we should be declaring exemptions and how they should be notated. Should I be putting the part and exemption? I doubt that exemption can apply to our final product since it is probably less than 1% of the total weight of the final assembly.

Also, please let me know how it should be stated if we HAD used leaded solder to make sure I am understanding all of this correctly.


Thank you!
 
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Ralba

Involved In Discussions
#2
I will give myself one bump then let the thread die.

Again, I am trying to understand if I would need to declare exemptions on my product on every issuance of compliance, or if I can just say it is compliant and give more details on how it is compliant if someone asks.
 

CharlieUK

Quite Involved in Discussions
#3
The guidance that you are looking for is in the RoHS Guide (my use of bold text):

Q8.11 What does a CE mark on EEE mean with regard to the restricted substances?
CE marking symbolises the conformity of the product with the applicable EU requirements imposed on the manufacturer. The CE marking affixed to a product therefore is a declaration by the person responsible that
- the product conforms to all applicable EU provisions, and
- the appropriate conformity assessment procedures have been carried out.
From 2nd January 2013 EEE in scope that bears a CE marking is presumed to be in conformity with the requirements of RoHS 2 and therefore is presumed not to contain more than the tolerated maximum concentration values as mentioned in Annexes II, III and IV of RoHS 2.

And if you look at the format for the EU DoC in Annev VI of the Directive, you won't find anything about listing applied exemptions.

Details of any exemptions that you apply should be documented in your Technical File and care should be taken that items have been "placed on the market" in advance of any exemptions expiring
 

Ralba

Involved In Discussions
#4
And if you look at the format for the EU DoC in Annev VI of the Directive, you won't find anything about listing applied exemptions.

Details of any exemptions that you apply should be documented in your Technical File and care should be taken that items have been "placed on the market" in advance of any exemptions expiring
After posting this, I looked extensively at the files and the declarations of other companies, and came to that conclusion, but I was not 100% confident. We decided to go with the conclusion until proven otherwise. Your response relieves some remaining anxiety about our execution on this subject, so thank you very much.
 

Ralba

Involved In Discussions
#5
I wanted to update this with information I was given. I emailed International Trade Administration (US gov) with this question back when I was posting this, and they replied. In case anyone searches this thread in the future to find the information I was looking for, I will post the response here. His reply is in bold.

...
What legally is the requirement for these declarations? Do we need to need to declare just compliance, or state in detail every exemption in the product?
The ROHS Directive does not provide instructions on the contents of the compliance declaration. It does require that manufactures hold records that substantiate the declaration.
 

CharlieUK

Quite Involved in Discussions
#6
The informer
What legally is the requirement for these declarations? Do we need to need to declare just compliance, or state in detail every exemption in the product?
The ROHS Directive does not provide instructions on the contents of the compliance declaration. It does require that manufactures hold records that substantiate the declaration.
The format for the DoC is given in Annex VI
A "Single" DoC must be produced covering all applicable legislation, so you might be listing 3 or 4 Directives and Regulations on a DoC
If you have correctly applied the exemptions, then your product meets the Directive

Article 7 requires manufacturers to record and keep evidence of how compliance with the Directive has been established - this is the requirement to hold records that substantiate the declaration
 
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