Start Compliance to RoHS, SCHV and REACH

A

abusuffian

#1
Hi, need some suggestion for company improvement.

1. Company Background
a. We are manufacture sintered metal products mostly for automotive sector.
b. Our raw material are metal powder which we used to make small automotive engine products

2. Existing RoHS Practise
a. Depends on customer requirement. If they requested for RoHS compliance lab test, we will send the related products to the lab. Then send them the result. or
b. If they just send form for us to refill related to RoHS compliance, we will check all raw material, chemical, lubricant and anti-rust oil and ensure all of these items don't have RoHS prohibited substances base on their CAS number.

3. My Question
a. Is the item (2)(b) is the correct way to identify any products are comply to RoHS? Is it mandatory to send to lab?
b. Can i use method (2)(b) for SVHC and REACH compliance verification?
c. Is it practical to request to all of our supplier to send their items (metal powder, chemical, oil, pallet, boxes, wrapping plastic) for RoHS compliance lab test? So our company can easily declare all of our products are RoHS complaince because we use RoHS compliance raw material. :confused:

Thank you in advance.
 
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#4
I would recommend starting with your suppliers - find out how much RoHS2 compliance information/test data they can supply (some are more giving than others I have found!). I believe you will want to specify RoHS2 as well.
 
J

JackPack

#5
3a - It is not mandatory to have test reports on the parts in your products. For your finished products your company must provide a Declaration of Conformity (DoC) stating that your products are in compliance to all relevant CE directives, ex RoHS2. Technical files are used to support the DoC. Technical files can be in the form of supplier declaration, and/or material declaration, and/or test reports. Technical files requirements are described by EN50581:2012. Which type of technical files you would like to provide depends on your customers' requirements, as well as the risks you assigned to the raw materials and the suppliers. Do the raw materials have a high chance of containing the restricted substances? Do the suppliers have a good track record? Are they trustworthy? etc.

3b - Hope you understand the way how REACH calculates the substance in the product. The SVHCs are calculated for the whole "finished product", vs RoHS which the restricted substances are calculated for each homogeneous material. If you can do the work yourself then I don't see any problem with method 2b.

3c - I think it will make it easier for you if you have test reports for your raw materials. Most customers (me included) are more satisfied when homogeneous materials are tested by a accredited 3rd party laboratory. I guess the question is are you able to convince all you suppliers to provide test reports, or are they only willing to give supplier declaration (Can be a red flag if they don't want to send their materials for testing)? You guys will have to work out the solution.

Hope this help a little.
 
A

abusuffian

#6
3a - It is not mandatory to have test reports on the parts in your products. For your finished products your company must provide a Declaration of Conformity (DoC) stating that your products are in compliance to all relevant CE directives, ex RoHS2. Technical files are used to support the DoC. Technical files can be in the form of supplier declaration, and/or material declaration, and/or test reports. Technical files requirements are described by EN50581:2012. Which type of technical files you would like to provide depends on your customers' requirements, as well as the risks you assigned to the raw materials and the suppliers. Do the raw materials have a high chance of containing the restricted substances? Do the suppliers have a good track record? Are they trustworthy? etc.

3b - Hope you understand the way how REACH calculates the substance in the product. The SVHCs are calculated for the whole "finished product", vs RoHS which the restricted substances are calculated for each homogeneous material. If you can do the work yourself then I don't see any problem with method 2b.

3c - I think it will make it easier for you if you have test reports for your raw materials. Most customers (me included) are more satisfied when homogeneous materials are tested by a accredited 3rd party laboratory. I guess the question is are you able to convince all you suppliers to provide test reports, or are they only willing to give supplier declaration (Can be a red flag if they don't want to send their materials for testing)? You guys will have to work out the solution.

Hope this help a little.
Your comment help me ALOT!! Very clear.. I read again and again.. Thank you very much..

However need to read more on you 3b answer.. Need more information for how the calculation done..
Very appreciate..
 
B

Badrul

#7
I would suggest that you use IMDS to declare your product substances since most of your product supply for automotive.
Now days most of the OEMs will accept it. You can attached you lab report as well but it is not mandatory.
By using IMDS it is more standardize because SVHC-REACH is already embedded in the system.
 
G

gstewart

#8
I'd like to pose a similar question.

We supply mechanical parts, made up of smaller components, largely to the automotive industry. As such many of the questionable materials have already been researched.

We have some small customers in the medical/electrical industry who request certificates of compliance to RoHS.

Now I don't want to go to a large number of suppliers asking about it.
If we have a drawing with an un plated mild steel component ( steel grade specified ) and they have internal PPAP approval for ongoing supply, can I therefore assume that it is steel of the correct grade that we are receiving?
I imagine that if it all turned sour, and it was found that we were supplying lead or something in our products ( not sure how this would happen ) then we could be sued. But since our suppliers are not allowed to substitute materials we could in turn sue them.

I don't want it to be a big deal , because it really only concerns a small number of sales.
 
B

Badrul

#9
Just to share how I did with my supplier.
In PPAP:pSW we always ensure supplier tick "Yes" in Material Reporting and submitted report by IMDS. Otherwise we'll reject the PSW.

Anyway there are some supplier have to use Lead. For us as long as the Lead is within concentration as stated in ELV Annex II we'll accept it.
 
G

gstewart

#10
This is a terrific way for "big customer's" to operate. Its called being the guy with the big stick. But the further you get down the supply chain the closer you get to being told where to stick your material reporting.
 
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