RoHS XV – The breathtaking fuzziness of the whole enterprise starts to become clear

emsnow.com is carrying a brief article, located at http://www.emsnow.com/npps/story.cfm?id=17790, about a mini-conference being put on April 18 at a hotel in Milwaukee, Wisconsin, that will focus on RoHS & “due diligence”.

“Due diligence” is a huge issue for RoHS, as a manufacturer who is found to be in violation of RoHS requirements will find their much of their fate resting on whether they can prove due diligence in trying to ensure their products met the RoHS directive.

However, “due diligence” is as poorly defined as most everything else relating to RoHS. Definitions of due diligence from various sources include (in increasing order of complexity):

  • Requiring written assurance of RoHS compliance from all component vendors.
  • Requiring Certificates of Conformity of RoHS compliance from all component vendors.
  • Requiring Certificates of Conformity of RoHS compliance, with specific declarations relating the maximum amount present of the six banned material classes, from all component vendors.
  • Requiring Certificates of Conformity of RoHS compliance, signed by corporate officers with fiduciary responsibility, with specific declarations relating the maximum amount present of the six banned material classes, from all component vendors.
  • Requiring Certificates of Conformity of RoHS compliance, signed by corporate officers with fiduciary responsibility, with specific declarations relating to the elemental & chemical compositions of all purchased components, from all component vendors.
  • Requiring Certificates of Conformity of RoHS compliance, signed by corporate officers with fiduciary responsibility, with specific declarations relating to the elemental & chemical compositions of all purchased components, from all component vendors. Additionally, sending out random samples from suspect or not-judged-trustworthy-and/or-competent vendors to independent labs for evaluation.
  • Requiring Certificates of Conformity of RoHS compliance, signed by corporate officers with fiduciary responsibility, with specific declarations relating to the elemental & chemical compositions of all purchased components, from all component vendors. Additionally, sending out random samples from all vendors to independent labs for evaluation.
  • Requiring Certificates of Conformity of RoHS compliance, signed by corporate officers with fiduciary responsibility, with specific declarations relating to the elemental & chemical compositions of all purchased components, from all component vendors. Additionally, sending out random samples from all vendors to independent labs for evaluation. Additionally, regularly sending out random samples from suspect or not-judged-trustworthy-and/or-competent vendors to independent labs for evaluation on an on-going basis.
  • Requiring Certificates of Conformity of RoHS compliance, signed by corporate officers with fiduciary responsibility, with specific declarations relating to the elemental & chemical compositions of all purchased components, from all component vendors. Additionally, sending out random samples from all vendors to independent labs for evaluation, both initially and on an on-going basis.
  • Requiring Certificates of Conformity of RoHS compliance, signed by corporate officers with fiduciary responsibility, with specific declarations relating to the elemental & chemical compositions of all purchased components, from all component vendors. Additionally, sending out random samples from all vendors to independent labs for evaluation, both initially and on an on-going basis. Additionally, sending out random samples of completed products to independent labs for evaluation, both initially and on an on-going basis.
  • Requiring Certificates of Conformity of RoHS compliance, signed by corporate officers with fiduciary responsibility, with specific declarations relating to the elemental & chemical compositions of all purchased components, from all component vendors. Additionally, sending out random samples from all vendors to independent labs for evaluation, both initially and on an on-going basis. Additionally, sending out random samples of completed products to independent labs for evaluation, both initially and on an on-going basis. Purchasing XRF machines for shipping & receiving, training employees in their use, and performing regular spot-checks of all incoming & outgoing products.

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