How to demonstrate it’s RoHS compliance

Compliance to RoHS Directive is mandatory in Europe for electric and electronic equipments, except for exclusions and exemptions, since 1st july 2006.
This means in practice that all equipments put on the market right now are supposed to be compliant.

However, recent studies showed that it was far from being the case. Manufacturers who made the effort to modify their products, sometimes at a very high cost, want to show clearly their compliance to this Directive.

Unfortunately, there is no marking and no certification defined by the European Commission to prove this compliance. “Self declaration”, based on the declarations of the suppliers about the components and on the own assertion of the manufacturer, is often subject to suspiscion on behalf of the customers.

However, manufacturers have 2 means today to reach this target.

First they may have their products analysed by a laboratory independent and recognized by the market. They can then show a lab report for a product or a range of products.
Analysis can be simply realized by X fluorescence or by chemical analysis.

However, The X fluorescence method presents a certain lack of accuracy, as it cannot raise the uncertainty on the Chromium 6 (Cr 6 or Cr 3) and on brominated materials ( PBB, PBDE or other). On the other hand the second method (chemical analysis) is more precise, but longer and more expensive.

The main disadvantage of the analysis method, X fluorescence or chemical, lies in the fact that it concerns a sample of the product, at the given moment. The manufacturer, and his customers consequently, have no certainty that lots of the same product, manufactured at a different time or using components and materials of different sources, will also be compliant to the RoHS norm.

The second mean fix this disadvantage. It is similar to the ISO 9001 certification (it uses the same chapters), as it is a process certification which takes into account all the product manufacturing steps, including the steps outside the company.
This Certification, called HSPM for « Hazardous Substances Process M anagement » is based on the IECQ (quality organisation of IEC) document QC 080000 and must be delivered by duly mandated assessors.
The Certificate delivered to the manufacturer will thus give evidence that everything is implemented in the company so that none of the forbidden substances (from the RoHS norm or from a specific customer requirement) has been able to be introduced in the product during the process. This guaranties the customer that the product is compliant, whatever the time and whatever the variety of supply sources or in case of subcontracting.

HSPM is relatively recent and few French companies engaged the certification process at the moment, while which is the main user today.

Most of the main international certification bodies are delivering HSPM Certificates. LCIE is the only one in France for the moment.

Our partner Jean Philippe Chizallet, from EcoCHANGE passed the HSPM lead assessor exam, and advises the companies which want to undertake this certification.