How to prove RoHS compliance

How to prove RoHS compliance is the question most frequently asked, once key issues such as lead-free solders and RoHS-compliant electronic components and materials have been sorted.

How to prove RoHS-compliance is the question most frequently asked, once key issues such as lead-free solders and RoHS-compliant electronic components and materials have been sorted following the implementation of the RoHS directive.

There is, unfortunately no quick answer.

Within the framework of the RoHS directive, it is the manufacturer - with responsibility for bringing the product onto the market - who has the opportunity to form and realise a self-defined strategy.

The measures chosen to prove RoHS conformity depends on several different factors and vary from company to company, and are often a question of resource and budget.

It is however clear that violation of the RoHS requirements will not remain unpunished.

An example of this is the attempt of a renowned internationally active electronics company that recently tried to roll out products in Europe via The Netherlands.

The Dutch authorities stopped the cadmium-containing import (contravening the applicable Dutch law), issued a fine of Eur 17 million and goods to the value of Eur 226 million had to be returned to be reworked.

Generally there are two options open to the manufacturer when it comes to proving compliance with the RoHS Directive.

These are: self-declaration based on external data and information; and declaration of compliance, either produced internally and/or following information and data checking by a third party.

Within the scope of the so-called self-declaration the manufacturer declares RoHS compliance based on company knowledge and information provided by its suppliers.

In effect this means that the manufacturer is ratified by its suppliers who confirm that the goods sold to them do not contain any of the six banned (limited) substances.

This proof is collected and consolidated for all components and materials in order to be able to prove RoHS compliance.

This is certainly an option permitted within the RoHS Directive, and it is easy to factor in and to verify the source from which relevant information comes.

But can the information from suppliers be trusted?.

Are there moments of doubt?.

Trust is good, but control is better - and here it is better to play safe.

The SGS Group, with 23 accredited RoHS labs worldwide and 3000 employees in this field, provides the RoHS analysis required to ensure trade and industry has the requisite independent data for an RoHS compliance declaration to be granted.

With chemical analysis methods an integral aspect of quality assurance, all suspicions and weaknesses can be uncovered and dispelled.

For the inspection of materials and components there are three main test methods from which to choose.

The XRF screening method is a fast, low cost portable test method with which to determine the required results.

However prior to use the subject to be examined should be checked the suitability for this type of testing.

The resultant findings are evaluated in accordance with the IEC62321, standard, version 1.

Where borderline values are concerned, a wet chemical analysis method should be used as a control test, for a high degree of accuracy and to produce the conclusive results.

XRF screening is essentially appropriate where information and data are already to hand, for example for a manufacturer checking goods in or receiving goods shipped from overseas.

It can be seen more as a control test method than a front-line test method.

Classic analysis methods, such as semiquantitative X-ray fluorescence analysis (nonselective for Cr-VI compounds and for PBB und PBDEs) or totally chemical laboratory analysis (selective for Cr-VI and PBB and PBDEs) are high-precision test and analysis methods.

RoHS testing takes place in a chemistry lab and is generally based on internationally standardised test methods (or draft standards) by way of calibrated measuring devices.

With the classic wet chemical analysis methods, these are a question of first measurement methods and are completely concordant with the directive and are the kind of analysis methods often found in the research and development for new materials and components.

In the future however they should be available to the processing industry in the context of product release prior to rollout.

Although this is not the case today, it is something worth striving for.

It is only possible for a manufacturer of end devices to declare RoHS compliance when in receipt of well-founded and "audited" information.

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