Do you have any messaging around the penalties and consequences of RoHS non-compliance that may resonate with my board of directors?
Based on experience, competent authorities from EU member states want to see evidence of RoHS due diligence showing that your company understands its requirements, and that third-party supplier documentation is being actively collected and refreshed. Significant fines and litigation are more likely to happen (compared to a corrective action plan) if a company flagrantly disregards this law and applies the CE marking without substantiation. Some EU RoHS enforcement authorities have stated that over $65 million worth of electronics are being recalled from the market every year due to this issue.
You should also be aware, especially for RoHS, that imported products are often scanned at customs to confirm they do not contain any of the restricted substances. From there, enforcement authorities can go back to the importer/manufacturer to determine what information they have that supports adding the CE marking. Even if they don’t specifically impose a fine, they can force you to remove/recall all non-compliant parts, which can get expensive.
**Article contents valid as of 2019-03-18