The issue of due diligence continues to confuse the electronics industry. Are material declarations enough? More and more voices in the industry suggest that if you’re not confident in your component supplier, you need to do some random testing of the components and add the test results to your compliance documentation package.
As for how the European Union is likely to verify compliance, the emerging belief is that EU member states will follow the recommendations of the European Information Communication Technology Association (EICTA) which has produced a “due diligence approach” toward enforcement of RoHS.The EICTA says that a company is presumed to comply if it puts its product on the market after the July 1, 2006 RoHS deadline.
If a competitor tips the governing body at an EU member that your product is out of compliance, the proof of compliance will be a package that includes your certificates of compliance, plus test results from iffy suppliers. If questions remain, the EU member country may test you product.