Reporting RoHS compliance

Producers must demonstrate compliance with the regulations by providing the enforcement authority (The National Weights and Measures Laboratory in the UK) with satisfactory evidence of such compliance in the form of relevant technical documentation or information. The UK intends to accept self-declaration as the basis of the compliance regime. The enforcement authority will carry out market surveillance to detect non-compliant products and may conduct tests for this purpose.

Producers may consider the following:

• Supplier declarations
• Producer analysis

The proposed approach to enforcement in the UK can be found at the National Weights and Measures Laboratory’s RoHS website www.rohs.gov.uk

Supplier declarations

Producers of electrical and electronic equipment (EEE) are able to obtain an assurance from their suppliers that any materials, components, assemblies or equipment provided do not contain more than the permitted levels of any of the six restricted substances, taking into account any relevant exemptions.

Producers are required to keep appropriate records for a period of up to four years after the particular product was placed on the market.

A variety of materials declarations for suppliers have been developed by industry. Some finished-product or end-product manufacturers publish such data on their websites.

Click Here for a sample materials declaration form.

Producer analysis

Producers of Electrical and Electronic Equipment (EEE) to be placed on the UK market can undertake their own analysis of the components or materials, either to verify supplier declarations or to establish the presence or otherwise of the restricted substances in those cases where no declaration is available.

Producers can employ any suitable analytical technique in order to establish that their products comply with the maximum concentration values of the six restricted substances. The criteria for analysis will depend on the quantity of product put onto the market (less for small producers than for large producers), the relationship with suppliers, the risk of a banned substance being present, and the potential impact of that substance on the environment. Producers must ensure that they understand and take into account any limitations of the analytical technique they use.

Use this flow chart to clarify the compliance process and whether testing might be appropriate.