Collecting RoHS and REACH Declarations is Difficult
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Why is it so difficult to collect good RoHS and REACH compliance declarations for my parts? What is happening that this is such a big problem?
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Collecting RoHS and REACH Declarations is Difficult
- 1. Reducing the Cost of Collecting RoHS and REACH Compliance Declarations RoHS Ready LLC Jim Kandler Dr Aidan Turnbull
- 3. Many Exceptions Compound to Suppliers are not trained Old Part data Supplier’s policies Various declaration types Increase Difficulty Suppliers have limited resources 100% of Suppliers must deliver for 100% of parts Sub-tier Supplier action is required Regulations change frequently Old Supplier data These exceptions are not your fault. But there are things you need to do to reduce the impact on your efforts
- 4. Still more exceptions Further Increase the Challenges Faced by ALL • The IT Tools don’t create and deliver the declarations, your supplier’s people do this. • IT Tools missing updates for the regulations. • IT Tools are missing needed features. • IT Tools not connected to the right internal data sources. • Your collection resources are limited, several ways. • Multiple interpretations of the regulations.
- 5. Further Complicated by People You have No Direct Control Over • Language • Geography • Experience • Education • Company Policy • Motivation • Interests
- 6. How Do You Handle Internal Process Exceptions? • What happens to requests when a supplier does not respond? • Does your team allow a supplier to request a later delivery date for the declaration? • Does your team track delivery of corrections by the supplier for declarations you rejected? • What happens when substance are found above the regulatory thresholds? Need to proactively address exceptions to keep all items making progress.
- 7. How Do You Handle Supplier Exceptions? • No such company. • No contact in the company found. • Supplier does not know about RoHS. • Supplier does not know the part number. • Supplier indicates, “This product is out of scope”. • Supplier requires a PO for analysis of the parts. • Supplier only sends declarations to customers. 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.
- 8. How do You Measure Your Program? • What are your Declaration Collection Process Metrics? • What problems are Limiting Progress? • Are we working on the Right Things today, and for next week?
- 9. What are Your Cycle Times to Collect Declarations? • How many days elapse from identified need for a declaration, to having the declaration accepted in your tool? • Is there a deadline that your team must accomplish? • Can you succeed with the current resources? • Is late delivery of declarations slowing product release?
- 10. What is Your Cost to Collect Declarations? • Do you know your total cost to get a declaration accepted in your tool? • Fully burdened Monthly Costs divided by # Declarations Loaded that Month. • $45? $35? $25? $?? Collection difficulties cause delays, require more resources, cost you more money. Not addressing exceptions guarantees they continue, FOREVER.
- 11. If You Apply Some Understanding, and Knowledge… RoHS Ready is able to accelerate your team toward EASY, MORE PRODUCTIVE, and LESS EXPENSIVE processes.
- 12. URL to presentation in SlideShare.net Enter in your Browser http://www.slideshare.net/JimKandler/linked-in-webex-201409r2- 38901796?qid=9f638fe9-9f4d-4088-9ce7-f41b80b15773&v=default&b=&from_search=1 Or Search ‘Jim Kandler’ or Collect RoHS’
- 13. 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.
Editor's Notes
- This presentation is based on my experiences, yours may be different. We will not discuss the details of the regulations, there are many others that do that. Instead we will discuss collection of compliance declarations. I find there are very few that are able to talk about this from first hand experience. This presentation will ask many questions, that I find need to be answered for progress to be made.
- This is an important statement that has not been made publically until now. This is the status of declaration collection today for most people.
- While there are many exception, this is not rocket science. Common sense applies here. Declaration Collect is DIFFICULT, initially……….
- Some of these exceptions are internal to your company, that does not mean that they will be easy to resolve. These last 2 pages do not list of the exceptions you may be experiencing.
- The solution provider tools to not deliver the needed declarations these people will You need to engage with the person on the other end of the phone or email: connect, communicate, and motivate You are dealing with people – extensive variation should be anticipated.
- The bulleted items are common instances where control of the supplier delivery gets lost. The loop needs to be closed or the effort invested will be lost. If you don’t monitor something you don’t know how it is performing. Know where you are going. On the next slide I will get into more details on requests that are not responded to.
- The supplier must be Ready, Willing, and Enabled. Exceptions affect 15 – 30% of companies or parts. Notice that the term Supplier is used. This can be the Manufacturer, Distributer, Wholesaler, Value added reseller, etc. All of these need to be engaged. I have found that a problem supplier for RoHS or REACH is also a problem for on-time delivery, part quality, & business financial risk.
- Activity is seldom an indicator of real progress. Ask quantitate questions Benchmark Others
- If your team is spending too much time on a part number or supplier they can’t work on the others that you need. Is 60 days too little or too much? Range is 15 minutes to 24 months
- Need to include the cost of emails, declaration reviews, edits to match the tool data, and tool input steps, and effort expended that is stopped by exceptions.. I my experience I have seen $45, which was able to be reduced by a factor of 5, to 1/5 of the original cost. Ask participants to indicate their cost in the question area.