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May 2014

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From:
Grunde Gjertsen <[log in to unmask]>
Reply To:
TechNet E-Mail Forum <[log in to unmask]>, Grunde Gjertsen <[log in to unmask]>
Date:
Mon, 19 May 2014 08:19:51 +0000
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The banned substances and the maximum permitted content (in each homogenous material) is exactly the same. 
Other than that there is a lot of important changes, the directive is now much more comprehensive and the scope has been expanded.
Most of these changes will not apply to you directly as an EMS company since you are in fact providing services and are not the legal manufacturer. (That is unless you actually provide a product and putting it on the european market as an OEM product or under your own brand.)

How much hassle it will be for you to provide the documentation necessary for your customers, (the legal manufacturers) to comply will depend very much on how solid the systems you have already established to manage RoHS, but do remember that a detailed material declaration is not required, if you can document that you have purchased and used a component declared and sold by the manufacturer as RoHS compliant you're good.

One thing that you must take into consideration is a certain level of traceability of the components and substances used in your manufacturing process as RoHS compliance is now included in the CE marking.
The manufacturers (your customers if you are an EMS company) is now required to be able to demonstrate compliance through the manufacturing process at any given time during the product lifecycle.
It is permitted by the directive for the legal manufacturer in agreement with the supplier to appoint an "authorized representative" which means that the supplier will provide these data on your customers behalf to the authorities upon request. 

I'd go over the revised directive, the FAQ as well as 768/2008/EC and EN50581. You may find these links useful:
http://ec.europa.eu/environment/waste/rohs_eee/legis_en.htm

http://europa.eu/rapid/press-release_IP-11-912_en.htm
http://ec.europa.eu/environment/waste/rohs_eee/events_rohs3_en.htm

Best regards
Grunde Gjertsen, Project manager, Kitron AS.


-----Original Message-----
From: TechNet [mailto:[log in to unmask]] On Behalf Of Dale Ritzen
Sent: 16. mai 2014 19:55
To: [log in to unmask]
Subject: [TN] RoHS 2 Requirements

Okay Technetters, need your help! This may be old news to most of you but I'm starting to get inquiries from clients that ask whether the components we use to build their products are RoHS 2 compliant. As far as I can tell from the research I've done, not much changed with the re-cast of the RoHS directive. I don't believe any new elements were added to the list of forbidden chemicals and mostly administrative changes were made to the directive. Maybe I missed something...

We also haven't seen a major rush from our component suppliers to document RoHS 2 compliance on their invoices/pack lists. In fact, I can't think of any that have used that updated text. All of them still use the "RoHS Compliant" statement, which I believe covers basically the same ground as stating compliance to RoHS 2. 

Anyone care to weigh in on the differences between the old/new directives and/or the necessity to document compliance to RoHS 2?

Thanks!
Dale Ritzen, ASQ CQA
Quality Manager / ISO Management Representative Austin Manufacturing Services

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