2 Replies Latest reply on Jun 1, 2017 3:45 AM by tailor

    RoHS 2

    cdorian56

      I would like to know if the Supplier Declaration for RoHS2 Conformity must be physically present (electronically or written) in the manufacturer's Technical Document File or is it acceptable to just link to the suppliers web site indicating the supplier is RoHS compliant.  The web site does not directly link to a declaration of conformance to your specific product but it just say we are RoHS compliant company.  I am thinking the Declaration of Compliance for the item number must be in the manufacturer's in-house file for each item.

        • Re: RoHS 2
          tailor

          Clause 4.3.3 of EN 50581:2012 (=harmonised standard of the EU "Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances") states that as a result of the Manufacturer’s assessment of RoHS, the following documents on materials, parts and/or sub-assemblies shall be collected: 

          1. Supplier Declarations and/or contractual agreement - Supplier declarations confirming that the restricted substance content of the material, part, or subassembly is within the permitted levels and identifying any exemptions that have been applied.  A contractual agreement includes the Manufacturer’s specification for the maximum content of restricted substances in a material, part or sub-assembly.
          2. Material Declarations providing information on specific substance content and identifying any exemptions that have been applied.
          3. Analytical test results using the methods described or referenced in EN 62321.

          So, in my opinion, you must collect documents, that show compliance with RoHS-2 or an exemption (for the list of exemption see Annex of  http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02011L0065-20160715). You can collect documents in written or electronicall fille. Also you shall evaluate trustworthiness of suppliers and quality of documents. For exemple, the document that declares RoHS compliance shall be refering specifically to the goods supplied, as you note above.

           

          For more information, I recomend you to read this practical guides:

          - http://greensofttech.com/site/wp-content/uploads/2016/04/Best-practices-for-RoHS-compliance-in-support-of-CE-marking_Apr…

          - https://www.bomcheck.net/assets/docs/Guide%20to%20Using%20BOMcheck%20and%20EN%2050581%20to%20Comply%20with%20RoHS2%20Tec…

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            • Re: RoHS 2
              tailor

              Just to be more specific, it isn´t absolutely necessary to collect all of document mentioned above (A and B and C). For ex. if your supplier is trustworthy, just "Supplier Declaration" can be suficient. What type of document is required depend on probability of hazardous substances in material (component) and the trustworthiness of suppliers. This question is discussed in the BOMcheck guideline...

               

              Best regards.