If you are handling Electrical and Electronic Equipment (EEE) you have probably heard of and are complying with the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment (RoHS 2) regulations. The question is, is the system you have in place effective or can improvements be made?
If you are not aware of the regulations, or you have not yet had to comply and might need to in the next couple of years when additional categories are brought into scope, then it is worth considering what you can do to set up an effective compliance system.
- Know your obligations
- Apply due diligence
- Whether you are considered the manufacturer or not, responsibility for compliance is shared throughout the supply chain
- Even if you do not initially have the obligation to draw up the required technical file you still have a responsibility to ensure the product is compliant
- Don’t just accept the paper work you are given, ask questions so you have confidence that the product is compliant
- Send products for RoHS testing if there is any uncertainty, or if the product could be deemed as high risk of non- compliance
- You may decide to include a statement in your terms and conditions, stating that on agreement of the terms your suppliers are confirming that their parts/products comply. You could also state that if products are found to be non-compliant they will be returned at the cost of the supplier.
- Have an auditable process in place
- Decide on how the RoHS compliance process should be carried out and keep a record of this
- This might include contacting suppliers on a rotational basis, ensuring your purchasing team know what questions to ask and what to look for in the products they are buying. Anything which demonstrates you are applying due diligence can be beneficial.
- Use a risk-based approach
- RoHS does not define exactly how to comply but we would advise taking a risk-based approach.It may not be feasible for example to test every product or every homogeneous material, so you may wish to assess the risk of potential non-compliance to minimise the number of tests required. Valpak can advise further on this if required.
- Comply with your obligations EU-wide
- RoHS is an EU Directive, applicable in each member state; therefore any electrical products in scope of the Directive should be compliant before they are placed onto the EU market
- We will keep you updated on any progression in relation to Brexit, but the RoHS regulations are transposed into UK law and therefore must be complied with until they are repealed or revoked
If you are interested in find out more about effective compliance systems, we are hosting an event in London on 10 May where we will be discussing RoHS and REACH. Please visit our website to book your place here.