Reducing the Cost of Collecting RoHS and REACH Compliance Declarations

RoHS Ready LLCJim Kandler Dr Aidan Turnbull

“Collecting ALL Required Substance

Declarations for RoHS and REACH is

very Difficult.”

Old Part dataSupplier’s policies

Various declaration

types

Many Exceptions Compound to Increase Difficulty

Suppliers have limited resources

100% of Suppliers must deliver for 100% of parts

Sub-tier Supplier action is required

Regulations change

frequently

Old Supplier data

These exceptions are not your fault. But there are things you need to do to reduce the impact on your efforts

Suppliers are not trained

Still more exceptions Further Increase the Challenges Faced by ALL

• The IT Tools don’t create and deliver the declarations, your supplier’s people do this.

• IT Tools missing updates for the regulations.• IT Tools are missing needed features.• IT Tools not connected to the right

internal data sources.• Your collection resources are

limited, several ways.• Multiple interpretations

of the regulations.

Further Complicated by People You have No Direct Control Over

• Language• Geography• Experience• Education• Company

Policy• Motivation• Interests

How Do You Handle Internal Process Exceptions?

• What happens to requests when a supplier does not respond?

• Does your team allow a supplier to request a later delivery date for the declaration?

• Does your team track delivery of corrections by the supplier for declarations you rejected?• What happens when substance are found above the regulatory thresholds?

Need to proactively address exceptions to keep all items making progress.

How Do You Handle Supplier Exceptions?

• No such company.• No contact in the company found.• Supplier does not know about RoHS.• Supplier does not know the part number.• Supplier indicates, “This product is out of scope”.• Supplier requires a PO for analysis of the parts.• Supplier only sends declarations to customers.

Need to close the loop on these, and remove them from the collection team efforts. Move the responsibility for the parts and supplier to someone outside of the collection team.

How do You Measure Your Program?

• What are your Declaration Collection Process Metrics?

• What problems are Limiting Progress?• Are we working on

the Right Things today, and for next week?

What are Your Cycle Times to Collect Declarations?

• How many days elapse from identified need for a declaration, to having the declaration accepted in your tool?

• Is there a deadline that your team must accomplish?

• Can you succeed with the current resources?

• Is late delivery of declarations slowing product release?

What is Your Cost to Collect Declarations?

• Do you know your total cost to get a declaration accepted in your tool?

• Fully burdened Monthly Costs divided by # Declarations Loaded that Month.

• $45? $35? $25? $??

Collection difficulties cause delays, require more resources, cost you more money. Not addressing exceptions guarantees they continue, FOREVER.

If You Apply Some Understanding, and Knowledge…

RoHS Ready is able to accelerate your team toward EASY, MORE PRODUCTIVE, and LESS EXPENSIVE processes.

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Jim Kandler, Managing Director, RoHS Ready LLCCollecting all RoHS and REACH declarations from all of your suppliers is often very challenging and expensive. Inefficient declaration collection process cause 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. Participate in the IPC 1752 Committee to further develop the IPC 1752 Standard.