UK guidance is shown below. Obtaining detailed analysis of each and
every component down to homogeneous level would not be practicable - be
pragmatic - the directive is asking you to take reasonable measures to
ensure compliance, not spend mega bucks trying to achieve the near
impossible. (The guidance document is available from the DTi website.)
Compliance
33. Producers must demonstrate compliance with the Regulations by
providing the
enforcement authority (on request) with satisfactory evidence of such
compliance
in the form of relevant technical documentation or information. The UK
intends to
accept self-declaration as the basis of the compliance regime. The
enforcement
authority will carry out market surveillance to detect non-compliant
products and
may conduct tests for this purpose.
34. There is no prescribed method to demonstrate compliance but
producers may
consider the following suggestions: -
Supplier declarations
35. Producers of EEE could obtain an assurance from their suppliers that
any
materials, components, assemblies or equipment provided do not contain
more
than the permitted level of any of the six restricted substances, except
where the
application of any of those substances comes within the scope of the
RoHS
Regulations' exempted applications. Producers are required to keep
appropriate
records for a period of up to four years after the particular EEE
product was
placed on the market.
36. A variety of materials declarations for suppliers are being
developed by industry
at the moment. Some finished or end product manufacturers are already
starting
to publish such data on their websites.
Producer analysis
37. Producers of EEE to be placed on the UK market may wish to undertake
their
own analysis of the components or materials that they use in their
products,
either to verify supplier declarations or to establish the presence or
otherwise of
the restricted substances in those cases where no declaration is
available.
Producers may employ any suitable analytical technique in order to
establish that
their products comply with the maximum concentration values of the six
restricted
substances. The criteria for analysis will depend on the quantity of
product put
onto the market (less for small producers than for large producers), the
relationship with suppliers, the risk of a banned substance being
present, and the
potential impact of that substance on the environment. Producers must
ensure
that they understand and take into account any limitations of the
analytical
technique they use.
38. At Annex D, you will find an example of a flow chart that has been
designed to
clarify the compliance process and could help producers determine when
analysis of components might be advisable.
Regards,
Chris
____________
-----Original Message-----
From: Leadfree [mailto:[log in to unmask]] On Behalf Of Blair K. Hogg
Sent: 18 May 2005 20:05
To: [log in to unmask]
Subject: [LF] Data gathering and maintenance requirement for RoHS
compliance
Avnet (US distributor) was here today making a presentation on a service
they are offering to customers (either free or for a fee, based upon
level of service) that will collect and organize data for RoHS
compliance. Something in their presentation stirred up a few brain cells
and I decided to go to this forum to see how everyone else is
approaching compliance, or demonstration of compliance.
Avnet will supply the materials content in ppm for each of the RoHS
substances, along with other component data such as weight.
I'm wondering if I really need this information.
The directive covers "homogenous materials" as needing to be compliant
and the accepted interpretation is that everything down to the plating
on the leads of a resistor must be compliant. I don't see where the
breakdown in ppm per part and weight are important. If I was taking the
approach that my product weighed 25kg, I could have 25g of lead and be
at the 100 ppm level, however, with the homogenous materials approach
this doesn't matter.
So what I am looking for is a statement from the supplier or
manufacturer that the part is RoHS compliant in itself. If all of the
parts I use are compliant, and my processes are compliant, then the
assembly is compliant by default.
Do I need the materials content data for anything? I have heard that
some customers are asking for this, as opposed to simply asking for a
statement of compliance.
Thanks,
Blair Hogg
QA Manager
GAI-Tronics Corp
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