There is no way for a small electronic company to sign a declaration while keeping a straight face.
Even obtaining the compliance statements from suppliers is impossible if you want to cover everything which might contain tin, tantalum, gold, etc.
I am sure 90% of people just lie and sign it, and everybody downstream is happy.
But, seriously, do the US-owned multinationals really kick suppliers off their supplier list if they don't get this declaration?
The statements usually begin with "to the best of our knowledge..."
You can add a blanket statement to POs to require CM certification on all parts. Big distributors will happily add a boilerplate compliance statement to every packing list.
Of course, it's all nonsense. There's no way we could know that the tantalum in a capacitor or the tin in our solder came from some bad guys. The big companies just want a statement from you to cover their asses.
-- John Larkin Highland Technology, Inc lunatic fringe electronics
I don't want to lie on such forms, so I just say I can't and don't. I have pushed back regarding a number of certs that customers want and I usually don't hear any more about them. Another one I can't deal with is REACH. I can and do submit RoHS paperwork. Most importantly customers have to accept *our* terms and conditions.
-- Rick
For REACH you need a PHD in chemistry, well almost.
2/3 of the stuff on the REACH list is never used in electrical components.It's gotten a little easier now, no %/w. Just Yes or No that it is present in the Article.
Cheers
John Larkin wrote
That's not an option. The old ROHS ways like the Control and Monitoring exemption (still valid now) don't work because all the big firms send you a spreadsheet form to complete. They won't accept your own declarations. They have departments which just hammer you with increasingly threatening emails until you return *their* document.
The big distis tell you to f- off if you are a small company. For example I tried this with the biggest UK one and they said they can do it if we submit a separate request for every component. It would take me days to get all the bits listed.
Yes but the bottom line is that you have to fake the answer e.g. the name of the smelter used. Unless you can make this correspond with some kind of commonly used smelters, the customer will suspect you just picked a name off the list of smelters (about 100-200 names on the list).
I should name a smelter for the tantalum in a capacitor that I buy from Mouser?
-- John Larkin Highland Technology, Inc picosecond timing precision measurement jlarkin att highlandtechnology dott com http://www.highlandtechnology.com
If it's going to cost you more to get the contract than the contract will pay, decline it, say that you're sorry that they are unable to buy your nifty stuff, and CC your letter to the company CEO.
-- Tim Wescott Wescott Design Services http://www.wescottdesign.com
I have never felt threatened by an email. I never return "their" spread sheets. I provide quotations on my form and let them deal with the transcription. There are too many issues (essentially legal) with providing data to them of a binding nature (meaning legally binding) without controlling the exact format.
That's not the same thing as telling you to "f off".
-- Rick
Tim Wescott wrote
The company couldn't care less. In most cases there are multiple suppliers, and compliance officers are the most powerful people in any company.
REACH is actually not hard, for UK firms, because of the govt guidance
If you are not a user of the chemicals then you just self-certify with a simple statement.
The problem is that all the big firms email out long spreadsheets which they want filled in, and they don't accept anything from the companies other than this spreadsheet.
That enables them to employ monkeys (e.g. a compliance processing dept in the Phillipines) who cannot understand what they are doing.
How long your non-response takes to lead to you being taken off the approved supplier list, that is the real question!
Indications I see suggest that Conflict Minerals is not taken too seriously simply presumably most suppliers are refusing to respond.
ROHS/REACH is more real, it seems. But only the most clued-up firms actually read your certificates and then come back asking for a ROHS2 one... But everybody has always lied about ROHS anyway. There is no checking and no enforcement - unless you do something very provocative. Like the CE mark, everybody is "ROHS" even if they use the (much superior) leaded solder. And there is the Control and Monitoring Equipment exemption which makes it impossible to enforce anyway.
In many ways I am glad I am nearly 60 and don't have to deal with this overpaid-compliance-vermin sh*t for much longer....
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