SVHC (Substance of Very High Concern) Declaration for Packaging Material

Q

qalsang

#1
Hi
Like to see one's input and comments on this :

Our end customer is in Europe.
However we supply our components to the customer's sub-contractors
in China for assembly.
In this case , is it still necessary for us to make a SVHC declaration
as requested by the end customers??
I think that this is not necessary as all the packaging material will be
disposed-off at China sub-con plant. Right??
 
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M

MIREGMGR

#2
Our end customer is in Europe.
However we supply our components to the customer's sub-contractors
in China for assembly.
In this case , is it still necessary for us to make a SVHC declaration
as requested by the end customers??
I think that this is not necessary as all the packaging material will be
disposed-off at China sub-con plant. Right??
Is a "request" by your customer equivalent, in their minds, to a specification?
If it is a specification, does it say anything about geographic bounds, i.e. REACH/ROHS reports/labeling are required only for shipments into the EU?
If they have provided a specification and it is not geographically specific, will they audit your compliance?
Will they be in a position to compare their audit of you with their audit of their Chinese subcontractor, to see if the various coordinating details match up? Is it possible that part of their business relationship with their Chinese subcontractor involves coordination of vendor-supervision efforts, with the subcontractor sending detailed receiving-inspection reports to the European customer?
If the European customer asks you if you complied with that provision of their spec, will you consider yourself obligated to respond honestly? If you tell them you did not comply because it didn't seem necessary, what would their response be?

My suggestion would be that whatever you were contracted to do, and agreed to do, you should do, and document that you did.
 
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