Scheme offers three routes to RoHS compliance

SGS has devised a modular RoHS compliance scheme for retailers and importers.

When considering the complex process of manufacturing electrical and electronic goods and products it is imperative to have an effective quality management system in place, able to manage the whole supply chain from raw materials to components and via the end-production stage to shipment.

As the retailer importing the goods and products into the European Union is responsible for meeting all European Regulations applicable to the product in question(such as the RoHS Directive), it is becoming ever more important to have effective and adequate test and control mechanisms in place to ensure and to prove that the "imported product" meets all necessary requirements.

The objective of the SGS modular RoHS concept for retailers and importers is to provide effective and adequate control mechanisms to ensure that the imported products meet the product specifications (agreed between the import organisation and the manufacturer) and all necessary RoHS regulations from the European Union, such as RoHS Directive 2002/95/EC.

Furthermore this concept can be combined with all other regular inspection services and other services of the SGS Group worldwide, such as final random inspection (FRI), during production check (DuPro) or quality/environmental management system certification.

The SGS modular RoHS concept comprises three modules, each of which deals with specific items (risks) within the whole manufacturing process.

The combination of various different modules enables the user to build his or her "tailor-made" quality and control system taking the actual (control) needs into consideration case by case.

The importer can decide whether he or she needs to control the complete process or just specific parts of the process.

Benefits of the SGS RoHS modular concept include: flexible and easy adaptation to the specific business needs; cost effective control of the manufacturing process; reliable and comparable results (because all laboratories use the same test methods); global availability through the SGS network of subsidiaries and laboratories; and the whole process is "tailor-made" for the retailer or importer.

The three main (basic) modules of the RoHS concept are: component (material) testing; technical inspection/screening; and the RoHS factory inspection/audit.

The first module follows the guidelines of the RoHS Directive 2002/95/ EC and requires chemical laboratory testing at the "homogeneous material" level.

The required tests must be carried out by an experienced and accredited laboratory following the test methods and guidelines of the Directive 2002/95/EC.

Most likely, the testing of basic components and materials will be handled by the supplier of the basic components and materials or by the end-product manufacturer, but typically not by the retailer/importer.

The test reports must be made available to the end product manufacturer and/or retailer/importer by the supplier of basic components and materials.

Without these test data and test reports, it is not possible to prove compliance with the RoHS Directive.

Therefore the retailer/importer must insist - by written contract, eg within the agreed product specifications - on receiving information on and insight into all relevant product and production data.

Otherwise the goal of importing products in compliance with the regulations of the European Union RoHS Directive will not be achievable and the declaration of conformity will not be possible.

This would be a violation of European Regulations.

In the case of missing test data and test reports, or in the case of any uncertainty/doubts regarding the quality or source of important product documentation, the retailer/importer must get the end product manufacturer to submit all test reports from component/subassembly and/or material suppliers.

If important information (test reports) is still missing, the "unit" in question must be tested at an accredited RoHS laboratory chosen by the retailer/importer.

The second module does not focus on testing basic materials and/or components (testing of "homogeneous materials" as required by RoHS Directive 2002/95/EC).

This module starts one step later in the production process and focuses on subassembled parts and final products, and the investigation and assessment of subassembled parts/final products.

The investigation method used in the second module is different to that in the first as the investigation of subassembled parts may take place in a chemical Testing Laboratory but can also be conducted in other locations, such as warehouses, customs, ports or production plants.

The module uses X-ray screening (using a portable test device) as a test method for detection and measurement of prohibited substances in electrical and electronic products and subassemblies.

The results gathered using the X-ray screening method are not as reliable as the methods used in the first module.

But the screening method is sufficient to determine whether the product is free of forbidden substances or if forbidden substances are present in the product at significant concentrations/levels.

X-ray screening provides a go/no-go statement combined with a test value for orientation (how good or how bad?).

The aim is: to provide quick test results for orientation; to keep the investigation costs as low as possible; and to be independent from laboratory facilities.

The scope of the investigation and the number of points to be measured using the X-ray screening method is directly related to the complexity of the product in question.

The X-ray screening method is after all not a 100% reliable substitute for the testing method used in the first module.

The test method used in the first module is the only testing method referenced by RoHS Directive 2002/95/EC.

The X-ray screening method includes a RoHS test report, which will be sent to the client within 2-3 working days: identifying the product/subassembly investigated; referencing the test method used; listing and identifying all points of measurement; identifying all points of measurement by taking digital photos; and listing the measured values for each point of measurement.

The third module focuses on the production process and the influences of the production process on the end-product.

This module is not so much a "laboratory approach" as an ISO9001/ISO14001 oriented setup combined with core safety elements of common Cenelec factory inspections.

The objective is to judge the capability of the end-assembly line (end-production line) to produce products, in full compliance with the requirements of RoHS Directive 2002/95/EC.

The elements included can also be customised to meet the special needs of the retailer/importer.

This module does not judge the safety relevant or performance aspects of a product leaving the end-assembly line.

It is purely focused on the important and relevant RoHS criteria.

This module, combined with the previous two, controls the complete supply chain (line purchase), in order to judge the RoHS compliance of the goods imported by the retailer/importer into the European Union.

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