Product category:
Capacitors
News Release from: Farnell
Edited by the Electronicstalk Editorial
Team on 27 October 2005
Due diligence defence requires evidence
Statements of compliance alone will not be enough to prove "due diligence" under UK legislation regarding the RoHS Directive.
Farnell InOne is warning the electronics industry to be wary of assuming that statements of compliance alone will be enough to prove "due diligence" under UK legislation regarding the RoHS Directive Laid before Parliament earlier this month, the legislation implementing the RoHS Directive in the UK provides a due diligence defence against the offence of putting a product on the market containing any of the banned substances at levels over those allowed
This article was originally published on Electronicstalk on 15 Feb 2005 at 8.00am (UK)
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This requires that all reasonable steps have been taken to avoid committing the offence.
However, there is no guidance on what is considered to be "all reasonable steps".
Steven Webb, General Counsel, Premier Farnell, comments: "This will be a judgment call, but our view is that it must mean something more than simply relying without question on what you are told by your suppliers".
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Webb explains: "Under the terms of the new regulations, it is clear that blind faith in a statement of compliance from a supplier of components or subassemblies is unlikely to be sufficient".
"It is therefore essential that electronic designers and engineers are carefully scrutinising the evidence provided by product manufacturers or are using a distributor which will do this for them".
To protect against this, Farnell InOne has developed its own comprehensive due diligence process.
First, creating a trail of data from its suppliers, requesting specific information on each individual product.
Secondly, each supplier undergoes a rigorous risk assessment and any high-risk suppliers are asked for independent test results or requested to demonstrate their processes which ensure banned substances can not enter the component.
Farnell InOne also carries its own programme of tests on selected high-risk products.
Finally, the company's meticulous warehouse procedures ensure all suppliers' labelling is scrutinised and compliant and noncompliant products are carefully segregated.
The international distributor issues unique part numbers for compliant parts, even if the manufacturer has not changed the part number, aiding segregation in its warehouses and assisting customers to track compliant parts in their systems.
Webb comments: "When a Farnell InOne customer receives a certificate of compliance from us, they can be confident that the individual component will have been through a stringent and rigorous process to confirm it is RoHS compliant".
"We take earning our customers' trust very seriously and will not take risks or shortcuts in our pathway to compliance".
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