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How do you prove compliance?
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.
Undetermined commented:
Mr.Olaf--sir, If I am not wrong, you could be from VISHAY (Formerly known as BC Components) I believe Suppliers needs to educated for re-placement of non-compliant materials & proper suorces. Kindly please let me know the Coatings, I can send you the Non-destructive test methods.
Undetermined commented:
Can you send rohs exempted list
Undetermined commented:
We manufacture parts which have electonics fitted to them, in various forms, these parts are/will be covered by RoHs, they are also coated to allow them to be corrosion resistant. Our suppliers cannot gaurantee cmpliance due to cost and coating types, therefore we are looking for methods of analysing the parts, non destructivly. The coatings are normally applied to Mild steel, but occaisionally can be on other materials, any suggestions on teting methods?
Undetermined commented:
Good point, especiall since there is an increasing number of anecdotal reports that testing on parts that are marketed as compliant are found to be non-compliant.
Undetermined commented:
Rob, I am not certain of the number of false or incorrect Certificates of Compliance that are out there. But I highly recommend that if a supplier is willing to issue a “C of C “ then they should be able to provide a complete material disclosure data sheet. Simple logic would dictate that if they don’t have the detailed information, how could they generate a “C of C” for RoHS compliance? In my seminars I make a straightforward statement, “in God we trust, all others provide DATA
Undetermined commented:
A material declaration for all components, fasteners, enclosures, boards, solders, etc, contained in your products is a good first step. You must also demonstrate that your business and technical processes ensure that you consistently produce products that comply. I suggest that you audit your entire business to determine where non-compliance can occur and modify your procedures to incorporate the necessary changes. You then need to set up an audit process to evaluate the effectiveness of the procedures and make changes based upon the audit results. Think ISO, document what you do, have the data on record to demonstrate that you follow the procedures, keep a record of the audit results and corrective actions. Due diligence is an ongoing activity, not a one time event for your company
Undetermined commented:
I was under the impression that industry had decided 'material declarations' as the best means of proving compliance and due diligence, based on what seems to have worked for the ELV directive. Do we have precedents in that case, of countries going beyond Declarations and asking for other test evidence? I ask this because of the enormous costs, if due diligence is meant to include testing of supplied materials.
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