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RoHS Compliance Responsibilities of Electronic Manufacturing Service Providers

Posted by Phil Holman on Aug 17, 2017 11:14:47 AM

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6 Organizational Segments and 3 Component Categories of RoHS Over Sight

If you produce any type of electronic equipment, you are impacted by the 2002 RoHS directive that seeks to eliminate the use of harmful substances used in the manufacture of electronic equipment. Non-compliance will restrict the sale of your equipment into Europe and also into many other countries around the world that are requiring RoHS compliance. If you designed a product to be used in the U.S., and are now looking to move into European markets, this discussion will be particularly helpful.

rohs compliant cable assemblies electronic manufacturing service providers.jpgUnless you’ve received an exemption extension for manufacture equipment that falls into category 8 (medical devices) or category 9 (control and monitoring equipment, or military equipment, or equipment used in military and national security use), you are already required to comply. 

As the whole world has moved towards RoHS compliance, companies have discontinued making non-compliant material, or will make it with increased MOQs, higher pricing, and longer lead times. As a result, many of the exempt companies have moved towards using all RoHS content to better support their supply chain, even though their products do not technically need to be compliant. 

The Sustainability Quotient 

Particularly interesting here is the “consequence” of the above scenario: many companies, by default, are already 80-90% RoHS-compliant with the materials they are using—even if the compliance mandate does not exist for their customers. The reality is that the efforts to explore a total switch to a RoHS-compliant supply chain are well worth it. Sometimes it can take as little as swapping out only one alternative part number to become 100% compliant. It can open a number of opportunities for businesses: companies increasingly want to work with suppliers that support sustainable initiatives, and it allows businesses to compete in European markets. 

The Liability Quotient 

This requires another article entirely, but it deserves mention in this discussion about responsibilities—and subsequently—liabilities. Certification, documentation, and traceability are requisite for a good process and are an established line of defense to ensure that materials are RoHS compliant. However, when a material, part, or component “slips by” and is in the field because it has not been validated though testing with an x-ray gun, the unwieldy chain of events that ensues is colossal and can be devastating to the supplier that is ultimately held responsible. A non-compliant in-field application compromises the entire supply chain. 

Logistically, how would you retrace all those steps to find the breach? The burden of proof is on the supplier and the process to establish that can turn ugly. Anything from tacit finger-pointing to lawsuits, damaged reputations and relationships, and being dropped entirely from multiple supply chains can ensue.   

Click here if you would like a free RoHS-compliant cable assembly assessment.

Have You Assessed Your RoHS Compliance? 

Whether you outsource your electronic manufacturing services or not, you are ultimately responsible for your company’s RoHS compliance. There are many elements and tiers of this to consider, but here is a quick, high-level overview of the in-house channels and some of the RoHS details that you are expected to maintain compliant over sight on. 

6 Organizational Segments 

  1. Quality Management: The RoHS requirements need to be a clearly defined and understood throughout the organization. Proper documentation must be in place and key stakeholders are responsible for implementation. A system should be in place to maintain technical files, including designs and bills of materials (BOMs). 
  1. Procurement: Make RoHS test reports available for raw material and/or components. Establish criteria for selecting RoHS-compliant material suppliers and clearly communicate RoHS requirements with suppliers and sub-contractors. Ensure they are clearly identified on the purchasing document, as well. 
  1. Incoming Goods and Storage: Proper storage involves segregation of RoHS raw materials and components to prevent contaminated mixing. RoHS materials and components need to be properly and systematically identified and tested, which involves having records that are accessible and traceable. A selection and release process needs to be in place. 
  1. Manufacturing: Processes for RoHS raw materials and components need to be implemented on the manufacturing floor regarding testing, identification, documentation, traceability, and non-cross-contamination workstations and tools. The workforce should be trained for full comprehension and execution of RoHS compliance. Appropriate controls for production changes must be implemented and a process in place for corrective or preventative actions when necessary. 
  1. Final Production: The process in place at this stage requires clear and proper identification of RoHS-compliant and non-RoHS-compliant products. Testing should occur and accessible records be in place for traceability. As in the production process, if there is any non-conformity, corrective or preventative actions must be taken when necessary. 
  1. Testing: In-house or outsourced, the factory is responsible for measuring the concentration values of the six restricted substances (lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyls or PBB, and polybrominated diphenyl ethers or PBDE). RoHS-compliant testing equipment uses hand-held x-ray equipment that examines the molecular structure of the material and tests it against the RoHS content thresholds to determine compliance. This requires trained personnel and a calibration process that is documented and traceable.  

3 Component Categories 

There are three basic categories of components regarding RoHS compliance: 

  1. Components that are RoHS compliant by the nature of their composition, and have been certified to be compliant, and in many cases are being sold under the exact same part number. 
  1. Components that were originally deemed non-compliant due to the material used in the manufacture of the product, or the manufacturing process itself being non-compliant. Companies have adjusted their material content or changed their manufacturing processes to become compliant. In many cases, the part number was changed or there was a suffix or prefix added to the core part number to distinguish compliant material from previously non-compliant material. Most of these products are direct crosses to the old part number and can be easily specified without impacting the performance of the end products. Some create special handling requirements, such as reduced heat or other special practices to allow them to be used in the application. Many of these products used lead in the manufacturing process, requiring them to be re-engineered to eliminate the lead content. 
  1. Some components were deemed non-compliant and had to be completely re-engineered to meet RoHS compliance. In some cases, the performance of the products changed significantly for certain product applications and could not easily be used to meet the requirements. In other cases, no compliant materials are identified that will meet the performance requirements of the equipment. In these cases, manufacturers have to apply for extensions to the exemption until new technologies can be introduced that will meet the RoHS compliance requirements and still allow the equipment to operate as intended in the application. These are the manufacturers with the biggest engineering challenges and will definitely reshape the future products in that industry. 

Click here if you would like a free RoHS-compliant cable assembly assessment.

What to Do to Become Compliant 

The good news is that many contract manufacturers have become experts in building RoHS-compliant products and can easily help an original equipment manufacturer (OEM) meet its compliance requirements as a natural part of their engagement.

Most contractors have built a database in their MRP system that will identify whether a component is RoHS compliant, and if not, can assist in identifying a RoHS compliant equivalent. 

While more people are educated about RoHS today, not as many people are invested in an advanced system to meet requirements through controlled processes, testing, practices, and scalability. RoHS currently covers six restricted substances, but is poised to widen the parameters to include other substances in the future. Among the many benefits of having RoHS standards in place on a system level is the ability to scale it to include additional substances when the requirements expands. 

The ability to test materials and products verifies, and acts as a safety net, for documentation and certificates and anything that may have been missed in the supply chain. The simple inverse view of this is: there is NO guarantee that the product meets requirement if it has not been tested.

Fourstar has a comprehensive plan for meeting RoHS compliance. Our system includes determining the RoHS compliance status of all material—starting with purchasing through receiving inspection—and ultimately when the material is issued and used to build a final assembly. As part of this process, Fourstar tests for RoHS compliance using a Thermo Scientific Niton model XLt797Y. Thermo Scientific Niton model XLt797Y.jpg

This portable x-ray gun breaks down the composition of the part, compares that to the RoHS requirements, and validates compliance or non-compliance. This is the only true way to confirm compliance to the standard. The gun can also be used at final inspection to validate that the completed assembly has not been contaminated in the manufacturing process. Some of the controls we implement as part of our larger RoHS compliance process involve designating RoHS-compliant workstations; soldering guns; stock, raw, and finished materials; and documentation. It is all clearly marked and color-coded to prevent cross-contamination. Having this adaptable, robust system in place allows us to be ready to meet the requirements when the standards changes.

At Fourstar Connections, we are fully equipped to transition you away from non-compliant content. We apply our project management, manufacturing expertise, exceptional customer support, and advanced IT systems to provide customers with a comprehensive range of products and solutions—from cable assemblies to complex box build solutions. Having 30 years of experience, and offering a comprehensive portfolio of services and solutions to tackle a wide range of manufacturing needs, Fourstar partners with leading companies to problem solve, innovate, and find better ways for new product introduction (NPI), and create design for manufacturing (DFM) initiatives.

FREE RoHS-Compliant Cable Assessment!

If you have a wire harness assembly or wire harness product that needs to be assessed for RoHS compliancy, we’ll test it against the RoHS content thresholds to determine compliance—for FREE.

Find out if your materials meet RoHS requirements. If so, that’s fantastic. If not, we can help you find a better way!

Yes, Assess My Cables for RoHS Compliance!

Topics: RoHS compliance, RoHS compliance for medical devices, RoHS compliance for security monitoring, RoHs-Compliant Cable Assembly Assessement

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Finding a Better Way

Fourstar partners with leading companies to problem solve, innovate, and find better ways for New Product Introduction (NPI) and Design for Manufacturing (DFM) initiatives.

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  • Advanced IT systems
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