MANAGEMENT + SYSTEMS
Test reports are required where the OEM does not view the risk of non-compliance to be low enough, through the conformity risk assessment documentation, or where technical documentation is not available. However, if testing is required, because a manufacturer cannot prove its processes are robust enough to comply with RoHS, this will result in multiple testing – every batch of products will need to be trialed adding to the costs and lead-time. Ultimately, if an OEM cannot prove that every component that
makes up a product and the processes used to make it adhere to the directive that manufacturer will not gain a CE marking for its product. For example, a washing machine manufacturer may have a complete product but without the technical documentation file and risk assessments it will not be able to apply a CE mark. Without the CE marking the manufacturer cannot put the product to market. OEMs will have a responsibility to inform the supply chain when a product needs to be RoHS compliant. However, to avoid problems further down the line fastener suppliers will really need to ask questions regarding the destination of the products. The whole supply chain has its part to play. Original equipment manufacturers must supply the technical
file and implement any actions identified as being at risk. Meanwhile, importers must review the technical file and ensure actions are taken if non-conforming products/risks are identified, such as introducing further manufacturing controls or testing. Finally, distributors must not sell a product if there is a ‘reason to believe’ that the supply chain is at risk and non-compliant product may be supplied.
“…the directive has changed the requirement from one of ‘Due Diligence’ to ‘Due Care’ - an important difference.”
What is key is that the directive has changed the requirement
from one of ‘Due Diligence’ to ‘Due Care’ - an important difference. Due Diligence requires the identification of threats and risks. Due Care requires action upon findings to mitigate risks. The target of this change is to drive increased compliance.
The implications of non-compliance
No technical documentation file No risk assessments =
No CE mark of approval No product to market
Penalties for lack of ‘Due Care’
Technical file The technical file is an essential document, which is added
to along the supply chain. OEMs produce the technical file for the design and production process. This includes materials, chemicals and contamination. The same details need to be available for all the sub contract processes. Distributors must then add their own file for their internal processes. TR Fastenings is looking at purchasing compliance – through a supplier risk assessment that will include: • Storage processes. • Picking processes. • Delivery methods.
Ultimately the OEM must then produce the final, complete documentation to achieve CE approval. TR Fastenings has already started to work with its internal
manufacturers to create technical documentation, and has just completed the first of three stages to provide technical documentation to one of its major OEMs.
BOMcheck One way to streamline the technical document process for
the whole supply chain is to join the BOMcheck system (
BOMcheck.net). TR Fastenings has taken the decision to join the BOMcheck system, alongside many of the major OEMs. There is a cost in being part of the system but it supplies
a robust tool for submitting full material declarations and compliance declarations to our customers, and allows us to receive the same from our suppliers. All technical documentation can be attached to the
submissions, to provide our customers with the evidence they need for their CE marking requirements. The system not only provides RoHS compliance details but
also takes into account many pieces of major legislation affecting our industry today. RoHS 2 is legislation that has industry-wide ramifications
along the whole supply chain. Everyone needs to embrace the changes now to ensure processes comply with the directive. Proving the process will radically change the way the supply chain works and the industry needs to pull together to successively manage this change.
110 Fastener + Fixing Magazine • Issue 72 November 2011
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