RoHS compliant? Think again…

May 16, 2006 in Latest, News Leave a reply

My son Alec got an 'F' in math once...Are you really RoHS compliant …

All companies selling into the EU and China should have their RoHS compliance efforts fully underway. With California and Korea RoHS dates just around the corner, this becomes a global issue. While many companies feel their RoHS work is completed, most do not they realize that they are fully exposed.

Here are two of the most common fallicies associated with RoHS compliance.

“My Distributor (or Contract Manufacturer or in-house engineer) converted our BOMs” – probably the most common answer, and very problematic.

“We are exempt”Even more of a problem and a potential nightmare when you find out why.

Read more on the huge "we are exempt" problem…

The RoHS directive provides little guidance on how to survive a RoHS compliance challenge. There are two basic audit worlds: the “Due Diligence” world, and the “Strict Liability” world.

Unfortunately, the typical result of having your Distributor, Contract Manufacturer or in-house Quality engineer perform your RoHS compliance work, is that you will not survive an audit.

Repeat that again:  you will not survive an audit.

Why? Because most companies have only a vague idea – thanks to confusing RoHS documents and individual country requirements – of what is actually required.

Audits will be more common in 2007Some EU countries fall into the “Due Diligence” camp – like the UK. They require you to take all reasonable steps to avoid the offense. They have indicated that some level of testing is required on an on-going basis.

Simply providing the RoHS certificate of compliance is not enough.

Testing, incoming inspection, vendor confirmation, risk analysis, change management procedures and traceability are all required.

The “Strict Liability” countries are an even more dangerous situation.  Due Diligence is not enough – if your products contain banned substances beyond allowable levels, you are guilty.  Vendor mistakes, manufacturing oversights or the lack of availabe lead free parts will result in fines and shipment stoppages.

Bottom line:  If you are not fully prepared for an audit, what was once an engineering problem is now a CEO and Board-level problem.

There is a good article by Steven Webb in Electronic Design about some of the steps needed to avoid the exposure. Well worth reading.

Want certified coverage all the RoHS Directives at once?…

John Taylor is the Managing Partner of Lead Free Design. They specialize in RoHS conversions, and the documentation and procedures required to help you survive an audit.


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