Who handles Your Reach, RoHS, 3TG Compliance


Involved In Discussions
Hi all,

I recently started at a new organization which does not have an environmental position or a compliance position.

So my question... Who really should be responsible for compliance matters to Reach, RoHS, and 3 TG? What department or individual role holds this responsibility within your organization?

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In large companies it could be a Legal Department thing, with an official "Compliance Officer" position. Some companies outsource the "Compliance Officer" duties.

In our small company its me (Sr. Quality Systems & New Product Development Tech), with assistance from our Purchaser in obtaining relevant documentation from suppliers. We only have official statements on REACH, RoHS & "Conflict Minerals".

If customers want other compliance docs our response is usually, "Sorry. These are what we have." I don't believe we've lost any business on account of that yet. Usually the individual doing the asking has no clue what the compliances are even for - its just on a list they ask everyone for.


Starting to get Involved
Hi dubrizo,

In our organization, responsibility for compliance to restricted substances/conflict minerals is a joint effort between our Quality and Purchasing departments. During product planning, Quality Engineering (myself) is responsible for verifying compliance by obtaining and reviewing objective evidence of compliance. For off-the-shelf parts, we request a completed RoHS or REACH Material Declaration, an independent lab Analysis or Chemical Composition, or Data Sheet with ROHS or REACH Declaration. All communication goes through our Buyer to better track action items.

Our suppliers are expected to take responsibility for the quality and material content of products supplied. We put in place agreements which they sign acknowledging their responsibility. We then require an annual update to existing declarations to cover any updates to the parts list.

Hope this helps.




Involved In Discussions
Ah, [dubrizo] - you fell for the trap.

Since you asked first, now YOU'RE responsible for it. :lol:

At least that's how it seems to go in my life - that's how I first got into the Quality field back in the early eighties.
Hahaha, I feel I'm always that guy who asks the questions that nobody else really wants to touch (unless it's their job.) I'm just too curious and don't have an issue challenging the status quo.

Can someone explain to me how environmental compliance (RoHS, REACH, 3TG) has been placed within the quality bucket for many organizations? Does it not make more sense to be a by-product of purchasing, seeing as they have the direct responsibility for and communication with their suppliers.


Trusted Information Resource
Well, as with so many things, the task falls to the person that is slowest to dodge when they are looking for someone to carry the burden.

The quality discipline tends to be a catchall for anything that could be vaguely justified.

Who such things SHOULD fall to is usually based on the three legs of the tripod - Responsibility, Authority, and Resources. Unless you have all three, your odds of success are low.

As the QA guy, I am responsible for seeing that Reach, RoHS, and 3 TG are dealt with, but I do that by asking that Engineering specify components that meet RoHS, and that Purchasing obtain certification for legacy components, and Engineering obtain it when they spec in new components.

Re 3 TG, in my industry, NOBODY at our level knows who the smelter is, so all we can attest to is good intentions coupled with ignorance.

REACH is a matter of risk assessment and information collection.

What was the question again? I think I'm going home now ... :bigwave:

Ronen E

Problem Solver
Whatever normzone said, he's right! :lol:

In my experience environmental compliance works best as a cooperation between R&D/engineering, QA and purchasing:

R&D/engineering should look for and initially verify compliant components/designs.
Purchasing should chase the necessary certifications on an ongoing basis (based on documented specifications).
QA should monitor regulatory trends and coordinate the effort.

We are into contract manufacturing and our engineering lead manages this, both online and offline with customers. This is more a technical compliance which requires engineering application rather than a pure legal.....


Involved In Discussions
In our organization I handle ALL environmental issues with the exception of conflict minerals. This includes IMDS, RoHS, ELV, REACH, EPA, DEQ and 14001.

My title is Environmental Coordinator and I work closely with engineering, quality, maintenance and purchasing to make sure we are in compliance with all customer, local, state and federal requirements.

I do not handle Critical Materials only because I do not purchase the raw materials so it was felt that it makes more sense to have our purchasing department take care of it. I gladly agreed.


Looking for Reality
Trusted Information Resource
Waited until it looked covered before I asked a potentially derailing question:

REACH, RoHS etc. I see discussed often...including by folks here in the USA.
But I see no discussions on USA OSHA GHS which takes 100x more work...

Is this something folks just aren't aware of? Or is it so big folks are afraid to talk about it?

Why is it such a silent topic? section 1900.1200.f.6 alone is way more effort than REACH compliance and filings...

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