REACH and RoHS Compliance for Digital Storage Media

Question: 

As a software supplier, am I required to provide compliance certificates for the disks or USB drives I deliver the software on?

Answer:

We need to ensure that all computer hardware, such as USB drives, conforms to both REACH & RoHS.

A USB drive is in scope of the RoHS Directive since it meets the definition of Electrical and Electronic Equipment. This means it must meet all requirements of the RoHS Directive, including demonstrating compliance. (Electrical and electronic equipment or EEE is defined as "equipment which is dependent on electric currents or electromagnetic fields in order to work properly and equipment for the generation, transfer and measurement of such currents and fields and designed for use with a voltage rating not exceeding 1,000 volts for alternating current and 1,500 volts for direct current".)

Reference - https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011L0065 

A USB drive is in scope for a variety of requirements under the REACH Regulation.  One of the primary drivers for supply chain communication to demonstrate compliance to the REACH Regulation is the need for communicating substances of very high concern (SVHCs) in Articles.  A USB drive is a complex Article and therefore will require this type of communication about substances in Articles. The European Chemical Agency (ECHA) responsible for REACH states that "Identifying substances in articles and quantifying their amounts is in many cases only possible if the respective information is made available by the actors in the supply chain. Supply chain communication is, therefore, the most important and efficient way of gathering the information needed in order to identify one’s obligations under REACH".

References: https://echa.europa.eu/documents/10162/23036412/articles_en.pdf/cc2e3f93-8391-4944-88e4-efed5fb5112c 

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011L0065 

https://echa.europa.eu/documents/10162/23036412/articles_en.pdf/cc2e3f93-8391-4944-88e4-efed5fb5112c 

Article valid as of 2019-01-18.

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