Certifying Assembly Components under RoHS

Q: Does every single component of an assembly (such as nuts and bolts) need to be certified under EU RoHS?

A: The requirement of meeting the RoHS Directive is to create a technical file that includes all documents on materials, parts and/or sub-assemblies. The acquisition/compilation of the documentation would be related to the materials/parts/sub-assemblies, as provided by the immediate supplier. It would not be expected for every company to directly get documentation from sub-tier suppliers, but it would be expected that direct suppliers have performed the same due diligence on their respective supply chains. The complexity of products/parts should be a factor in assessing the risk of products.


This content is accurate as of  March 15, 2019.

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