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August 2005

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Subject:
From:
Camille Good <[log in to unmask]>
Reply To:
(Leadfree Electronics Assembly Forum)
Date:
Tue, 23 Aug 2005 13:22:48 -0700
Content-Type:
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Phil,

You have a couple of different issues in your e-mail.


Dealing with your second issue first:  If your
component supplier says they are providing
RoHS-compliant components, how do you KNOW they are?
This is a question that all of us are having to deal
with.  Depending on how conservative (or paranoid) you
are, you might want to send random samples of
components out for 3rd-party testing on a regulat
basis. However, what I think most people are doing is
getting certificates or statements of compliance* from
their suppliers and making sure they have
traceability.  IF your product gets tested by the EU
and IF it is found to be non-compliant and IF that can
be traced to a component which the component
manufacturer told you was compliant, then the EU is
supposed to go after the component supplier.
Unfortunately, I don't know the directives well enough
to give you an exact clause or sub-clause number, but
I remember there was a discussion on this group a
while ago about this, so maybe someone else on the
group knows which clause says that?

Regarding your first issue: How do you specify which
plating to use?  I would talk with your plating vendor
and discuss the technical issues with them,
specifically asking them what processes use what
plating.  Ask the supplier for a certificate of
compliance* for that particular process.  Also ask
them how that should be speced on the order you place
with them, and then make darn sure that all P.O.s and
drawings specify those particular processes.
Additionally, you can also ask the plating vendor to
include some type of compliance statement or
certificate with each shipment of plated parts.

* - I have seen no formal templates for the
certificate of compliance.  The general rules of thumb
I have seen is that the certificate must be written;
it must be on company letterhead; it must specifically
state the process/product is RoHS compliant; it must
specifically spec the process or product by part
number, or part family, or say all products from that
supplier, or SOMETHING so that later you can argue
that it did specifically cover what you bought from
that vendor; and it must list all six materials banned
under RoHS and their maximum allowable concentrations.


You may wind up with two certificates of compliance -
one from the aluminum chassis provider saying the
aluminum chassis is RoHS compliant, and one from the
plating vendor saying that their plating processes
will not add any of the materials banned by RoHS.

Hope that helps,
-Camille Good
Portland, Oregon

--- Phil Nutting <[log in to unmask]> wrote:

> This may be outside our groups purview, but I'll ask
> it anyway.
>
> For our aluminum chassis sheet metal we have
> historically used Yellow
> Irradiate.  The information I'm getting for making
> this RoHS compliant
> is to make sure the plating vendor used trivalent
> chromium rather than
> hexavalent chromium for either clear or yellow
> irradiate.
>
> It is also my understanding that there are similar
> "rules" for zinc
> plating.
>
> The real question is, how do I specify this on my
> assembly drawings and
> purchase orders?
>
> Am I going to get a true RoHS compliant plating?  I
> can't be the only
> person with this issue!
>
> I'm sure I can go into did the plater have a
> dedicated RoHS plating
> tank, is he telling me he complies but in reality he
> just lies?
>
> Hey, I'm a cynic.
>
> Phil Nutting
> Design for Manufacturing Engineer
> Kaiser Systems, Inc.
> 126 Sohier Road
> Beverly, MA 01915
> voice: 978-922-9300 x1310
> fax: 978-922-8374
> e-mail: [log in to unmask]
> <mailto:[log in to unmask]>
> www.kaisersystems.com
> <http://www.kaisersystems.com/>
>
>
>
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