Suggestions for environmental compliance with small machinists?

#1
Hi,

First time posting here! I'm collecting documentation to demonstrate our product's compliance with REACH, RoHS, and Conflict Minerals directives. For components purchased from well-established suppliers, this is a more or less straightforward process. However, our product contains a number of custom machined parts that we source from small, local machinists.

First question: if they sign a supplier material self-declaration form (e.g. by signing we declare all deliverables to X company comply with the following directives: RoHS, REACH, Conflict Minerals Rule) and then I work with them to ensure any RoHS exemptions, above-threshold REACH SVHC presence notifications, and completed CMRT are on file, will that be sufficient documentation of their conformity? or lack thereof :/

Second question: currently when batches of parts are delivered from these machinists, we receive no accompanying material disclosure or material certification. I also can't find anything in writing that indicates that they are retaining this information as quality records. Due to my lack of familiarity with the machining industry, I'm hesitant about what sort of paper trail is reasonable to ask for, and I don't want to damage our relationships with these smaller suppliers by making unreasonable demands. However, we have a downstream customer that expects us to maintain material traceability to the lot/batch level. Would asking for material certifications to be sent with each batch delivery be unreasonable or unnecessary?

Apologies if this or similar questions have already been answered - I tried searching the threads, but may have missed a useful posting.
 
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DarisS

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#2
Hi,

First time posting here! I'm collecting documentation to demonstrate our product's compliance with REACH, RoHS, and Conflict Minerals directives. For components purchased from well-established suppliers, this is a more or less straightforward process. However, our product contains a number of custom machined parts that we source from small, local machinists.

First question: if they sign a supplier material self-declaration form (e.g. by signing we declare all deliverables to X company comply with the following directives: RoHS, REACH, Conflict Minerals Rule) and then I work with them to ensure any RoHS exemptions, above-threshold REACH SVHC presence notifications, and completed CMRT are on file, will that be sufficient documentation of their conformity? or lack thereof :/

Second question: currently when batches of parts are delivered from these machinists, we receive no accompanying material disclosure or material certification. I also can't find anything in writing that indicates that they are retaining this information as quality records. Due to my lack of familiarity with the machining industry, I'm hesitant about what sort of paper trail is reasonable to ask for, and I don't want to damage our relationships with these smaller suppliers by making unreasonable demands. However, we have a downstream customer that expects us to maintain material traceability to the lot/batch level. Would asking for material certifications to be sent with each batch delivery be unreasonable or unnecessary?

Apologies if this or similar questions have already been answered - I tried searching the threads, but may have missed a useful posting.

Hello gliese581,
As you are mentioning that you are procuring custom made components, I'm guessing that you own the design of those parts and therefore you have defined the raw material your suppliers must use. They are therefore not responsible for the RoHS and REACH compliance as they have no choice of what material they must use to manufacture your products.

The only risk is if the use the wrong material, but if this is the case you then not only have a breach in your RoHS and REACH system but potentially a quality problem as the material used my not fit your product technical requirements.
As a good practice, I would recommend that you request material certificates with every delivered batches.
You may also need to check your supplier management system to make sure you are selecting and evaluating your suppliers with rationales that will bring you the confidence that the supplier has a good quality system and a good material traceability system.

Regarding the Conflict Material sourcing, based on the above, if you own the design and the raw material definition, you must know what parts contain conflict minerals. You can then focus only on the supplier that are manufacturing your components made of material containing conflict minerals. The easiest is to request them to complete a CMRT form.
Hope it helps...
Daris
 
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