This is a UK based answer!

Reasonable steps cannot be universally defined because they vary depending upon the situation. Guidance is available but no definitive rules.
We have one customer who puts millions of product on the market per year, their definition of reasonable steps is to spend £50k on a machine, employ a group of chemists/physicists and qualify every item in their product themselves. Another customer we have put a few hundred products on the market each year and a reasonable step for them is for us to use reputable component suppliers and retain evidence that the components are RoHS compliant (CofCs). Both of these reasonable steps may be considered OTT, adequate or inadequate by the agent for the secretary of state, in our case NWML. We won't know until NWML ask for evidence of compliance.
The article in EW was very unhelpful. CofCs may be evidence of reasonable steps if you have done a risk assessment of the source of the CofC. Again NWML would decide that when they examine evidence of compliance.

I think the most important point is that doing nothing is definitely not acceptable. If you do risk assess your suppliers, do retain evidence of compliance then you can at least show some evidence to NMWL and can have a sensible discussion about how to 'improve' if they feel it necessary. NWML can issue a compliance notice to get those 'improvements.

'Reasonable steps' can be got through Google
E.g. http://www.askcedric.org.uk/modules.php?modid=5&chapid=20&sec=4

Trading Standards offices often have examples of reasonable steps on their web sites. Some give good examples e.g. where Boots (A big UK chemist chain) got prosecuted where the reasonable step was 'big & expensive' but within the capability of Boots and the risk generated was high (Lead in paint on a toy, I think) whereas a small company was acquitted as there was no further reasonable step that the small could have taken.

I hope this helps.
Rex
 

-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Scott Xe
Sent: 09 February 2006 17:09
To: [log in to unmask]
Subject: [LF] Conformity certificates will not satisfy RoHS legislation

In ElectronicsWeekly.com, NWML said a statement of compliance from a supplier of components or sub-assemblies is unlikely to be sufficient.  It suggests to take more reasonable steps to avoid committing the offence.  What are the reasonable steps?  I have learnt that UK government has issued a final RoHS guidelines and is there any suggestion in there?

Scott

-------------------------------------------------------------------------------Leadfee Mail List provided as a service by IPC using LISTSERV 1.8d To unsubscribe, send a message to [log in to unmask] with following text in the BODY (NOT the subject field): SIGNOFF Leadfree To temporarily stop/(start) delivery of Leadree for vacation breaks send: SET Leadfree NOMAIL/(MAIL) Search previous postings at: http://listserv.ipc.org/archives Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100 ext.2815
-------------------------------------------------------------------------------

________________________________________________________________________
This email has been scanned for all viruses by the MessageLabs SkyScan service.
________________________________________________________________________



This email has been scanned for all known viruses by the
MessageLabs SkyScan service.
================================================================
This email (including any attachments) is confidential and/or may be legally privileged.  It is intended for the named recipient (s) only and may not be forwarded, disclosed or otherwise disseminated 

Although this email has been scanned for viruses, WE DO NOT (to the extent permitted by law) ACCEPT ANY LIABILITY WHATSOEVER for any virus infection, compromise of security or losses resulting from vi

NO CONTRACT MAY BE FORMED OR DOCUMENTS SERVED BY THIS EMAIL unless specifically agreed to in writing and signed by a Director of Hansatech.  Any views or opinions expressed in this email are those of 

If you have received this email in error please contact the IT department immediately on  (01202) 674 333 or (01553) 691 022 prior to deletion.
================================================================

-------------------------------------------------------------------------------Leadfee Mail List provided as a service by IPC using LISTSERV 1.8d
To unsubscribe, send a message to [log in to unmask] with following text in
the BODY (NOT the subject field): SIGNOFF Leadfree
To temporarily stop/(start) delivery of Leadree for vacation breaks send: SET Leadfree NOMAIL/(MAIL)
Search previous postings at: http://listserv.ipc.org/archives
Please visit IPC web site http://www.ipc.org/contentpage.asp?Pageid=4.3.16 for additional information, or contact Keach Sasamori at [log in to unmask] or 847-615-7100 ext.2815
-------------------------------------------------------------------------------