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.
Collecting RoHS and REACH Declarations is Difficult
Reducing the Cost of Collecting RoHS and
REACH Compliance Declarations
RoHS Ready LLC
Jim Kandler Dr Aidan Turnbull
Many Exceptions Compound to
Old Part data
100% of Suppliers
must deliver for
100% of parts
action is required
These exceptions are not your fault. But there are things you
need to do to reduce the impact on your efforts
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.
Further Complicated by People You
have No Direct Control Over
How Do You Handle Internal Process
• What happens to requests when a supplier does
• 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.
How Do You Handle Supplier
• 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.
How do You Measure Your Program?
• What are your Declaration Collection Process
• What problems are Limiting Progress?
• Are we working on
the Right Things
today, and for next
What are Your Cycle Times to
• 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
• Is late delivery of declarations
slowing product release?
What is Your Cost to Collect
• 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.
If You Apply Some Understanding, and
RoHS Ready is able to accelerate your team toward EASY,
MORE PRODUCTIVE, and LESS EXPENSIVE processes.
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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.