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RoHS Audits Prove Due Diligence

A RoHS audit can significantly reduce, or eliminate, the risk of producing non-compliant products. This means incorporating RoHS requirements into your quality system's review process and implementing a RoHS training program must be key priorities.
By now, we should all be familiar with the European Union's RoHS Directive (Restriction of the use of certain Hazardous Substances in electrical and electronic equipment). Companies that anticipate selling their products within the EU are expected to comply with the member state laws that implement the directive by taking all reasonable steps and exercising all due diligence to ensure their products comply.
"Reasonable steps" is pretty straightforward. But what exactly is due diligence? According to the U.K. National Weights & Measures Laboratory (NWML), due diligence is simple: have systems and procedures in place that are effective and that provide proof of compliance.
Your organization may have developed a Quality Management System, which is ISO certified. The problem is that ISO certification does not address the specificity of the EU RoHS requirements. As it relates to RoHS, is your system adequate? Is it being used and can you prove it?
Design Chain Associates recommends that a comprehensive quality system, if not already in place, be established and implemented. A vital component of this quality system is the audit process. An audit process will serve as an excellent tool to be used by your company as it endeavors to meet the objectives of the RoHS requirements. The purpose of an audit is to provide a checklist by which a company's ability to comply with the requirements of RoHS regulations is assessed. A controlled system, which focuses heavily on prevention and detection of errors early in the product development process can greatly reduce, if not eliminate altogether, the risk of producing non- compliant products.
As the product manufacturer, you must be able to demonstrate your ability to consistently ship compliant product. Your existing quality system must be enhanced by incorporating RoHS requirements into the review process. Your training objectives must be updated to include RoHS training, which is both adequately detailed and well documented. Although these steps provide a general overview of the scope of a RoHS audit, much more depth and detail is required.
When reviewing a training plan or program specific to RoHS include the following questions:
For which positions within the company is RoHS training required? How is employee competence determined as it relates to RoHS requirements? How does the training program ensure that new and existing employees are aware of the relevance and importance of their activities relating to RoHS? Ask yourself if your supplier surveys contain pertinent questions about how RoHS materials, components and documentation are disclosed and controlled. For example, your survey should contain questions such as:
Does the supplier have systems in place for controlling their documentation related to RoHS compliance?

Does the supplier provide evidence of compliance in the form of documentation and component testing?

What processes are in place to ensure that the supplier and subcontractor can consistently ship RoHS-compliant components/subassemblies?

Does the supplier/subcontractor control their inventory — separating compliant from non-compliant material? When conducting an internal audit, extend your reach beyond the traditional areas of purchasing, production and inspection. As the manufacturer of a RoHS-compliant product, your responsibility for maintaining compliance extends well past the time the product leaves your facility.
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SGS Taiwan LTD. Taipei Multi Chemical Laboratory t: +886 2 2299 3279
Ext.3103-3124
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SGS Taiwan SGS Taiwan LTD. Kaohsiung Multi Chemical Laboratory t: +886-7-3012121
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The SGS Group is the global leader and innovator in inspection, verification, testing and certification services. Founded in 1878, SGS is recognized as the global benchmark in quality and integrity. With more than 56,000 employees, SGS operates a network of over 1,000 offices and laboratories around the world.