When is necessary to have RoHS declaration on non-electrical parts?

[Igorwara]

Hello all,

hope someone can help me to clarify this issue.
We are assembling our products from approx 200 different parts, which we buy from different suppliers all over the world. Our final product is electrical so we need to declare it for RoHS.
My question is regarding parts, which we buy from suppliers and on their side this part does not contain electrical parts, so they claim it should not be declared RoHS from their point of view - e.g. screw, plastic valve, cable marker... but we mount these parts to bigger assembly/product which already has electrical parts and therefor needs to be declared against RoHS. Do I have right to ask suppliers with screw, plastics valves, cable markers, ropes to declare me RoHS?
Because if I think about it, I put screw into final product, which we need to declare RoHS, but how I should know that the screw does not contain some of the RoHS restricted substances if the supplier claims that RoHS is not needed, because from his point of view it is non-electrical screw, without RoHS.

thanks
IW

 

[planB]

Do I have right to ask suppliers with screw, plastics valves, cable markers, ropes to declare me RoHS?

Depends on what you have agreed with your supplier, preferably in a written contract. Communication is key: explain to your suppliers why you are in need of these certificates and explore what kind of material declarations they are willing to share: e.g. if a supplier stated that the screws are made of stainless steel only (ie. 100.00%), then you could self-declare RoHS conformity for this component. Have a look into IEC 63000:2016 for further guidance on how to assess material compliance.

Hope this helps,