Supporting Compliance Requests as a Distributor vs. as a Manufacturer

Question Posed:

We are a distributor company, buying products from manufacturers and selling them to end users. As distributors, how do we respond to questions and make declarations? Are these not supposed to come directly from the manufacturers?

Answer Provided:

Distributors have the option of providing the name of the manufacturer and contact information to get the compliance information or request it from the manufacturer themselves to pass on. On the other hand, manufacturers should be confirming their products are meeting the requirements and providing the necessary notifications to downstream recipients if their products contain any of the regulated substances.

Note: The European Conformity (CE) Marking on Electronic and Electrical Equipment (EEE) indicates that the product meets the requirements for EU RoHS (either does not contain any of the restricted substances over the 0.1% threshold or is compliant by exemption).  But the documentation to support the marking is necessary.

Reference: https://osha.europa.eu/en/legislation/directives/regulation-ec-no-1907-2006-of-the-european-parliament-and-of-the-council 

Reference: https://echa.europa.eu/regulations/reach/downstream-users 

***Article contents valid as of 2017-10-13

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