Have You Observed Issues Collecting RoHs and REACH Compliance Declarations? Review of some of the likely causes and mitigating actions. This was presented at the Vienna Green CARE Conference. There were about 60 people that attended this panel discussion setup by Dr. Aidan Turnbull. I asked the attendees, “Who here has not experienced issues collecting declarations?” One person raised their hand to shoulder height. So everyone has issues collecting declarations. It does not need to be this way, as the one person in the room very timidly indicated. When some gaps are addressed and measures are implemented it can get much easier.

1. Have You Observed Issues Collecting RoHS and REACH Compliance Declarations?
RoHS Ready LLC
Jim Kandler Managing Director
www.RoHSReady.org
jim@RoHSReady.org

2. Symptoms You Might Observe
1.Declaration Collect is too slow, very delayed, or late completing, can’t keep up
2.Frequently expediting important declarations
3.More money is required for unplanned efforts, since previous efforts didn’t deliver
4.Your product releases are delayed by missing part declarations
5.Your customers are upset by late delivery of declarations

3. Collecting ALL Required Substance Declarations for RoHS and REACH is Very Difficult.

4. Action is Required by Suppliers’ People
•Language
•Geography
•Experience
•Education
•Company Policy
•Motivation
•Interests
The Variations Produce Numerous Exceptions

5. Exceptions Must Be Managed?
1. No Supplier response to requests
2. The specified part is obsolete or not RoHS
3. Part specification is vague, can’t declare
4. No contact information for a supplier
5. Substances are declared
above the regulatory
thresholds?
Need to proactively address
exceptions to keep all items
making progress.

6. No Response to Requests
1.No such company.
2.No contact in the company found.
3.Supplier does not know about RoHS.
4.Supplier does not know the part number.
5.Supplier indicates, “This product is out of scope”.
6.Suppler provides declarations on their web site.
7.Supplier requires a PO for analysis of the parts.
8.Supplier only sends declarations to customers.
9.We are only the Distributor, we don’t have any data.
Need to close the loop on these, and remove them from the collection team efforts. Move the responsibility for the parts and supplier to someone outside of the collection team.

7. Progress Indicators are Needed
1. Can the existing team get the declarations
before planned product release?
2. Can Customer requests be delivered in 45
days?
3. Can the team
keep up the flow?
4. Are there other
options to meet
requirements? What are your Declaration
Collection Process Metrics?

8. Cycle Times to Collect Declarations
•How many days elapse from identified need for a declaration, to having the declaration accepted in your tool?
•What is the average, best case, worst case?
•Can the team keep up with the current inflow?
•What is causing the worst case responses?

9. What is Your Cost to Collect Declarations?
•Do you know your total cost to get a declaration accepted in your tool?
•How do your efforts compare to others?
•$45? $35? $25? $??
Collection difficulties cause delays, require more resources, cost you more money. Not addressing exceptions guarantees they continue, FOREVER.

10. If You Apply Understanding, and Knowledge…

11. Jim Kandler, Managing Director, RoHS Ready LLC
Collecting all RoHS and REACH declarations from all of your suppliers is often very challenging and expensive. Inefficient declaration collection process cause many manufacturers to spend far more than they need to. Product releases may be delayed by incomplete CE Mark technical files. Collection process exceptions are often not being escalated. We will apply our declaration collection experience in a review of your current practices. Opportunities will be identified to lean the processes and greatly improve throughput. Afterward, you will have effective, efficient, and reliable processes that will not hinder your business.
RoHS Ready Managing Director, Jim Kandler led the GE Healthcare Sourcing effort to collect substance declarations for 250,000 parts. Worked with the other core team members to set up company-wide procedures. Built a team that collected 150,000 declarations from 6,000 suppliers; many of these through BOMcheck. Loaded collected declarations into PTC InSight, ENOVIA MCC, Gensuite PCC. These efforts included RoHS, REACH, and Packaging. Participate in the IPC 1752 Committee to further develop the IPC 1752 Standard.