RoHS Technical File - Step by Step - Transcript

Hi! Here is an example of how you can compile your RoHS technical file by gathering manufacturers’ declarations of conformity. It is a four-step process. Let’s get started.

Step 1 - Preparing the BOM to Build the RoHS Technical File

BOM Preparation RoHS

First of all, you receive a BOM (or a bill of material) for a specific product. Let’s open it!

That will be here in the first file. 

You see here: it shows my BOM. Let’s see how many parts we have there. It’s an example. It will be very simple. BOMs can be much bigger than this one. You see, here, are four parts. So what you need to do is to compile these parts into folder number three, which is the supplier and material confidence assessment.

If you open it, you will see the first three columns which are the ones that you to fill in. The information is:

  • the manufacturer’s part number;
  • the manufacturers or suppliers name; and
  • your part number, the internal part number. 

So, let’s do that! 

Okay, so it’s done now!

Now, we can move on to step two. And don’t forget to save. Now, we can do our first RoHS research!

BOM Preparation RoHS 2

Step 2 - Doing the RoHS Data Gathering

How do we do it? It’s very simple! Let’s take the first part: part number zero zero zero one. And, we’re going on these suppliers’ websites.

RoHS 2 Online Research

So, let’s do a Google search with this company: CUI! This is just an example. Then, you will search, maybe, the part number. Then, let’s do the manufacturer’s part number and the company’s name is appearing. You see, here is the company’s website. It’s always better to have the actual company (manufacturer) than a distributor. So, let’s go to the manufacturer’s website and search. You can look at the company’s information if you have any environmental compliance details. They could be in About us. They could be elsewhere. You can look at the very bottom of the website. You see here: Quality Center. You may find good information. You see material compliance, products life cycle that could help.

If you look in more details here, you see there is an email address. It’s always interesting to have. And a statement!

First Example: A RoHS Compliant Part without Exemption

Now, in this example, if you enter the part number, you have a specific statement for this part. So let’s take the most specific one. You see, here, it says RoHS and REACH, which is another regulation. But you have a whole statement for your part number.

  1. So, you need to make sure we’re talking about the right part number. Yes, it is! It could be the part number or a series. It’s fine as well.
  2. You need also to verify if we are talking about EU RoHS and not on other laws, regulations. Here, it’s clear. It’s EU RoHS. It refers to the right directive with the amendment 2015/863, which is an interesting one because it refers to the phthalates that were added to the list. 
  3. Do you see these phthalates here? So you do have ten substances, and that’s another piece of information that you must find in the certificate of compliance. Make sure that there are ten substances. It could be explicit like that or implicit by mentioning the right directive and the amendment.
  4. The last piece of information is the exemption. So, you see, there is no exemption. Here, it’s very clear. It could be explicit like that or implicit. But, it has to be clear enough that you understand whether or not there is an exemption. 
RoHS Certificate of Compliance Example

Archiving the Declaration of Conformity

This document is perfect. Therefore, you need to fill in folder number three. Here, you know, YES, it is RoHS compliant, in Column F. You will fill in compliance with EU RoHS: YES. And NO, there are no declared exemptions. So here, you would enter NO. Otherwise, that would be the exemption number. You will need to verify if the exemption is still valid.

Don’t forget to save it, and then you also need to save this document. Print it and, you would save it. Create the supplier’s name. Create the folder inside of folder 2 Supporting documentation. Then, you give a name. It could be the part number or any. The name shouldn’t be too long, no longer than one line. It could be the name you prefer. You need to keep this

evidence as proof, a demonstration that the part is indeed RoHS compliant. So you finished the research for the first part!

Second Example: A RoHS Compliant Part with an Exemption

RoHS Keywords Research

Let’s try the same exercise for the second part number. Do we have anything more accurate than just, you know, this logo? We don’t know what it is about. Let’s go under diodes.com. You can use different keywords. For example, RoHS is a good keyword. Let’s try that! We will find a statement. Part Number is another very good keyword. Oh, maybe we found something here. Let’s try that one. Oh, there is a whole list. 

If you zoom in a little bit, you can read and recognize the directive: RoHS 2011/65/EU, and the amendment 2015/863, for the phthalates. That’s useful! You also even have a list of restricted substances. 

Four Details you should Find on a RoHS Declaration of Conformity (DoC)

Now, you need to remember the four pieces of information you need to find out:

  1. the part number or the series number
  2. Number two: whether it’s EU RoHS. We just found that. Yes, they cover EU RoHS. 
  3. Do they cover the 10 RoHS substances? It looks like they do here. 
  4. And the last question is: What about the exemptions? Is my part compliant under an exemption, or is it compliant without any exemption? Let’s search here. Do a Control+F. Oh yeah! Look! It’s here!

Yeah! The part contains lead. There is an EU RoHS exemption. So, the part may be compliant under exemption 7A. Let’s save this document.

4 Details on a RoHS Declaration of Conformity DoC

Valid EU RoHS Exemption?

Now, we need to verify if exemption 7A is still valid because RoHS exemptions have expiring dates. They can have expired. It’s not obvious. We don’t necessarily know. On getenviropass.com, under Substances Control / RoHS / Europe RoHS. At the very top of this page, you will see the list of exemptions. Let’s search exemption 7A. Where is it? It’s here! Right here! 

So you can list it. Declare here: YES, the part is RoHS compliant, and there is a valid exemption, which is 7A. So you will write 7A. Let’s take the most simple way of declaring the exemptions. Everything’s in capital letters. 

Third Example: Missing Information for a Robust RoHS Technical File

Let’s now take the example of the third part: zero zero zero three: the QT Brightek part. Let’s do the same exercise.
Here, it only says RoHS compliant on the datasheet. Usually, datasheets are not comprehensive enough. And you see this RoHS logo. It doesn’t say much.

Online Research of RoHS Statements

  1. Let’s go to the company’s website. If you spend more than five minutes searching on the website, it’s because the information is probably not there. 
  2. Another thing you could do is go to some distributors’ websites. If they give you a link directly to the declaration of conformity from the manufacturer, that would be good. So, let’s search! Maybe on Digikey. Here is a link to a declaration of conformity. Let’s see if it’s good enough.

Managing the Available RoHS Information and Archiving tit in the RoHS Technical File

RoHS 1 - 6 Substances
  • Do we recognize the part number? They say all LED products. Your product is a LED. So, yes, it’s covered. 
  • Another question: is what about the exemptions? They don’t specifically say:  the part is compliant without exemption. But they say here ND, for not detected. Then, there is no exemption for the six substances.
  • So really, here, the issue is that there are only six RoHS substances, not ten. 

But we can still archive it. It’s better than nothing. Thus, I would save it in folder number two. Document it. So in your file number three of the excel spreadsheet. Here, you will write something in the comments. And you would send an email or an online request to this manufacturer. Use our Enviropass Product Environmental Compliance (EPEC) form. It’s free. We keep it up to date. You click on download. 

Fourth Example: Customized Part and Drawing Sheet with Material Information

Let’s look at the fourth part: the top plate. There is a part number here. And this one is a custom part. It’s often a mechanical part. And on the, drawing you may have the specifications of the materials and the finishes. So, it’s very interesting for us to have that because if we do have the specifications, the material breakdown, we will be able to verify compliance. It must cover every homogeneous material, including the material itself and the finish: everything that is part of the product.

Reading the Materials on a Drawing Sheet

Here is the drawing sheet, or the technical drawing, that we’ve received for this part. You see, here: top plate

The same rules apply. You need to make sure we’re talking about the same part. You see, here, there is the part number. If we look at these specifications, you see, here, there is a material reference: C84500. And there is no finish. So no finish, we don’t have to worry about finishes. And the material, we need to verify what is the chemical composition of this material, C84500. 

Drawing Sheet Material Details

Then, let’s look at it. You see, there is some literature, some information that you would find online. Here, the chemical composition. You see, it shows a 7% t lead. It’s a copper alloy. It is above the general threshold of 0.1%.

Searching for a Potential RoHS Exemption

Now, it may be under an exemption. You will find there is one exemption for copper alloys. It is exemption 6C here. However, a 4% lead is accepted. Here, you have a 7% lead. 

Let’s search C84500. You see, it’s here. It’s listed on this blog page, in table 4: Examples of copper alloys and their compliance.

What do they say? They say: concentration is above 4% for leadAnd it’s tagged as a non-compliant alloy. 

Entering the RoHS Status of the Custom Part

You need to report that as well under your file number 3 and you’ll write NO, it’s not RoHS compliant. And NO, there is no exemption for it. So, you write NO. 

How do you document it? You would save that technical document.

Step 3 - Sending Requests for the Missing Information of the RoHS Technical File

Step three: this step applies once you’ve achieved steps one and two for the parts without sufficient online information, like part 3. You must send a request to the supplier.

  1. Ideally, you would send directly the request to the actual manufacturer
  2. If there is no email address available, then, you would send the online request
  3. If there isn’t even an online form, you may want to call the supplier or the manufacturer and get the right email information to submit your request. 
  4. You will write it in comments, like Email Sent, here.

Then, you would send all of your emails to the suppliers with missing information for their parts. 

Here is an example of an email you can submit to manufacturers that don’t show enough RoHS information on their website, like the example we had. 

And you would say: 

Dear supplier, Enviropass (or your company’s name) is looking for the following information: Can you please fill out the, etc.

And you give the right tabs from the EPEC form: the Supplier Information and RoHS tabs. You give the link to make it clear for the supplier, and you give all of their part numbers that don’t have sufficient RoHS information. 

RoHS inquiry to Manufacturer - Example

Step 4 - Following-up with Manufacturers and Completing the RoHS Technical File

Then step number four is a weekly follow-up by emails. You can

even call suppliers just to:

  • be sure that they’ve received your request and they are working on it; or
  • be sure you have the right email information.

And you follow up with them. You will find any relevant document or communication.

I hope you’ve found this tutorial useful. Subscribe to the Enviropass Youtube channel to get more tips on product
environmental compliance!