11 Declaration Acquisition Methods to Meet RoHS

RequirementsThere is more than one way to ‘skin a cat’.

While this presentation is focused on RoHS II, many of the declaration acquisition concepts presented may also be applied to other substance

regulations.

RoHS Ready LLCJim Kandler Managing Directorwww.RoHSReady.orgjim@RoHSReady.org

The RoHS II RequirementsBefore the product is imported into the EU, you must have evidence in hand that enables you to declare your product is compliant to RoHS.• CE Mark, needs a summary document in the Technical

File that indicates current technologies are implemented (it meets the RoHS requirement).

• Business and quality processes must be followed that demonstrate that everything is under control.

• All of the details are archived for 10 years and maintained (in the solution provider tool) going forward.

• Most people get this report from their solution provider tools.

The Task in Front of You

The objective is to get all needed declarations for your products into your tool, so that the products can be completely evaluated for RoHS Compliance.

• Your job, and the suppliers are to generate the needed declarations, and load them.

• The solution provider tool will evaluate and archive the part declarations and rollup the product compliance.

Methods Available to Declare Your Parts Compliant to RoHS1. Exclude Out of Scope Parts

2. Initial Screening for No Risk Parts

3. CE Marked product that is in scope today

4. Self Declare the Part

5. Supplier & Material Confidence

6. Request a Declaration from Your Supplier

7. Join a Centralized Web Declaration Sharing Tool

8. Purchase from Declaration Sellers

9. Contract 3rd Party Collection Services

10. Hire a Turn-Key Service Provider

11. Homogeneous Materials Testing of the Parts

Exclude Out of Scope Parts

This is a quick way to remove extra parts from your list. Determine if the parts are:

• Pre RoHS product service parts

• Expendables

• Out-of-Catalog non-EE

• Accessories non-EE

• No material content

Find the out-of-scope parts and get them identified as such in your tool.

Initial Screening for No Risk Parts

This is a quick way to remove parts that are no risk. If the material specified can’t contain RoHS substances:

• Clear Plastics

• Tempered Glass

• Wooden Box

• Elementary substances

Find the no risk parts and get them identified as such in your tool.

CE Marked product in scope today

This is a quick way to parts that are RoHS compliant because of the CE Marking. Look for the CE Mark on the product and identify that they are a category of product that is in scope already.

Find the CE Marked parts and get them identified as such in your tool.

Self Declare the PartIf the materials of the part are fully specified, you might be able to write a declaration from that. Many times this can be Class D FMD. Often these are custom parts.

Self Declaration can eliminate the need to request the declaration from the supplier.

Supplier & Material ConfidenceEN 50581 allows for an assessment of the Supplier and Material to access the risk of RoHS substances and handling of them per the results.

More rigor is applied where

there is increased risk, less where

there is less risk.

Request a Declaration fromYour SupplierThis is the usual method, which is required when the supplier controls the purchased part and there are several component parts (vs the previous self declaration).

• You are responsible for working the list of needed declarations to completion

• Need to address the multiple gaps that will prevent obtaining 20-40% of the declarations

• Need acceptance criteria for delivered declarations

Join a Centralized Web Declaration Sharing Tool

• Users pool efforts and all benefit

• Metcalfe’s Law

• You match your list to the participating suppliers

• Many gaps will be found

• Need acceptance criteria for delivered declarations

Purchase from Declaration Sellers

• Bulk purchase of thousands of part declarations that they already hold in their dB

• Usually electronics and standard hardware

• They match your list against the declarations they collected and sell matches to you

• Many gaps will be found

• Need acceptance criteria for delivered declarations

Turn Dollars into Declarations very quickly.

Contract 3rd Party Collection Services• They make requests to suppliers and receive

declarations for you. This is replacing your people with the 3rd party people doing the job instead.

• Paid by the man-hour or number of items on your list.

• Older and very unique parts tend to be a problem

• Many gaps will be found

• Need acceptance criteria for delivered declarations

These guys can address parts that are a gap for the Declaration Sellers, but this takes time.

Hire a Turn-Key Service Provider

• They take over everything

• Make requests to suppliers, receive declarations, and load into tool, run reports for you

• Provide the tools, training, and project management

• Paid by long term agreement

• Older and very unique parts tend to be a problem

• Many gaps will be found

• Need acceptance criteria for delivered declarations

Unfortunately this is Never completely Turn Key.

Homogeneous Materials Testing of the Parts• Send parts to a laboratory for their analysis

• Make a declaration from the results

• The supplier has no interest to comply with a declaration when updating parts

• Very expensive

Select Multiple Methods to be more Successful

Self Declaration Supplier Requests

Purchase Declarations Exclude the Part

Web Sharing Screen out No Risk

CE Marked Supplier & Material Risk

Out-of-scopeGaps/Exceptions

Resolved Gaps/Exceptions

In Conclusion

• All of the methods indicated will result in gaps. No one of these will deliver 100% of what you need

• Use a blend of these (except Turn-Key) to control costs, match up with supplier processes, and meet needed delivery dates

• Your efforts will be required to close the gaps/exceptions

• Solution Provider Tools are very necessary, but don’t get the declarations

If some one says they can deliver 100% either walk away or get it in a litigable contract.

Jim Kandler, Managing Director, RoHS Ready LLC

Collecting all RoHS and REACH declarations from all of your suppliers is often very challenging and expensive. Inefficient declaration collection process have caused many manufacturers to spend far more than they need to. Product releases may be delayed by incomplete CE Mark technical files. Collection process exceptions are often not being escalated. We will apply our declaration collection experience in a review of your current practices. Opportunities will be identified to lean the processes and greatly improve throughput. Afterward, you will have effective, efficient, and reliable processes that will not hinder your business.

RoHS Ready Managing Director, Jim Kandler led the GE Healthcare Sourcing effort to collect substance declarations for 250,000 parts. Worked with the other core team members to set up company-wide procedures. Built a team that collected 150,000 declarations from 6,000 suppliers; many of these through BOMcheck. Loaded collected declarations into PTC InSight, ENOVIA MCC, Gensuite PCC. These efforts included RoHS, REACH, and Packaging. Participated in the IPC 1752A Committee to further develop the IPC 1752A Standard.

Symptoms of the Problem

•Declaration Collect is too slow, very delayed, or late completing. •More money is required for unplanned efforts, since previous efforts didn’t deliver. •Your product releases are delayed missing part declarations. •Your customers are upset by late delivery of declarations.

Our ActionsWe will apply our

declaration collection

experience in a review of your

current practices. Opportunities

will be identified to greatly improve

throughput and lean out the processes.

The Results

You will have effective,

efficient, and reliable

processes that will not hinder your business.

References• COCIR GUIDANCE, ROHS 2 OBLIGATIONS FOR COMPONENTS AND

ACCESSORIES - APRIL 2014

• COCIR GUIDE ON ROHS II DIRECTIVE APRIL 2013, OBLIGATIONS FOR MEDICAL DEVICES

• RoHS FAQs, http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf.

• BOMcheck.net, by “Guide to Using BOMcheck and EN 50581 to Comply with RoHS 2 Technical Documentation Requirements.” June 2012, Section 3.3.1 https://www.bomcheck.net/assets/docs/Guide%20to%20Using%20BOMcheck%20and%20EN%20505081%20to%20Comply%20with%20RoHS2%20Technical%20Documentation%20Requirements.pdf

DisclaimerThis presentation is the property of RoHS Ready LLC, and does not indicate preferences or recommendations by RoHs Ready. The points made in the presentation are a generalization of the current condition, they are not all inclusive.

The Slide deck is available

www.RoHSReady.org > Resources > Methods You Can Use to Meet the RoHS Declaration Requirement

http://www.slideshare.net/JimKandler/8-methods-you-can-use-to-meet-the-ro-hs-declaration-requirement