Are your compliant parts really compliant?

Panasonic components tells people to go directly to the distributors for compliance data, this does not make sense, the manufacturer should know compliance conversion dates. Molex isn't even keeping track of conversion dates

I would argue that the involvment of testing may break your "system of compliance". Once you start to do testing, we have had to decide what to test/not-test, which involves a company judgement. You company might be concluded quilty if non-test parts are found non-compliance. In addition, you could not conduct testing on semiconductors in homogeneous base per directive where as you have had to accept declaration. Large company suppliers are not necesary trustable as it always report mis-conduct in News headlines. Hence, the testing as part of compliance system will put company as high risk since there are always opened rooms for challenge on decision in what materials to be tested. In addition, selective testing also systme inconsistence from system perspective.

I did ask that question. While the information is propretary, an exectuive did explain that high-risk companies tend to be those outside North America that have been working with the distributor for less than one year. Other factors include types of components. Some well-known companies such as Texas Instruments go automatically to the low risk column due to their leadership in environmental compliance.

I would like to hear from some distributors in regards to what they believe their financial RoHS liability is. In the past distributors took no responsibility for manufacturers electrical data sheets. If I had a problem with a part they always pointed me to the manufacturer for resolution claiming that it was the responsibility of the component OEM and myself to resolve the issue. When we say distributors I believe we should also be clear about what type of distributors are we talking about. There are basically two types of distributors; factory authorized distributors and distributors who source parts from various sources and then resell them. The key question to ask is, are you a factory authorized distributor, clearly not all distributors are the same in regards to service and support. I would also ask if they are members of a recognized industry group that sets high levels of conduct. The example that I would point out is NEDA. The bottom line question you want to ask your distributors is what financial liability do they have if they sell a part that is sold as RoHS compliant and it is later determined to be not compliant. As a “producer” who runs the risk of fines, removal of product from the EU Market, not to mention all of the resulting bad press, you are ultimately held responsible. If you as a producer cannot get a complete material data sheet for the parts, either from the manufacturer or the distributor, you need to take appropriate actions to seek alternate sources or design out the parts and replace them with parts from suppliers who can give you what you need. If a distributor discovers, by whatever method they choose, that a supplier has made a false claim in regards to RoHS compliance they need to notify their customers and begin a recall of the parts. They should purge their stock and remove the supplier from their line card until such time as the supplier has provided evidence that the problem has been corrected. Are the distributors will to take this action?

Depending upon if the finish they use is either large grain or small grain matte tin will have an effect upon the likelihood of tin whiskering. Many accept the idea that large grain tin is less likely to grow whiskers compared to small grain tin. In this, I am out of my areaq of expertise.

Yes, I keep hearing that the small component suppliers with fewer resources are the ones to worry about. Those suppliers are also more likely to use a pure tin solution which may increase the liklihood of tin whiskering in products with a multi-year lifespan.

I'm not so concerned about some of the larger manufacturers like TI, Analog Devices, Linear Tech, National, etc. It's the smaller fringe manufacturers that I worry about. A recent effort by our company to find a specific RoHS compliant connector was a lesson in frustration. The larger manufacturers hadn't yet made the conversion while quite a few of the offshore manufacturers were claiming compliance and providing documentation. But we have no idea if the part in question is actually compliant. It's all going to be a question of "Sorta kinda of trust, but verify..." If we want our customers to trust us then we'll have to do the due diligence and test the component(s) in question.

I don't blame them either. I've talked with a number of distributors on this subject. They've been advised by their legal eagles to keep a distance from vouching for their suppliers. As one distribution executive put it, "We were not there when these parts we're manufactured, so how can we make any claims on how compliant they are?" At least one distributor -- Newark InOne -- has identified risky suppliers, and the company is sending some of those components out for testing. Not surprisingly, they're finding that some of the parts that are marketed as compliant are not compliant.

This might explain why some distributors are taking a hands-off position when it comes to RoHS compliance documentation, leaving it to the part manufacturers to provide declarations and certificates. They don't want to deal with the liability if a part is non-compliant even though the documentation provided by the manufacturer claims compliance. Frankly, I don't blame them.