If a customer requests REACH or RoHS compliance documents on parts that have not been in production for a number of years, can we submit documentation based on the REACH/RoHS lists dating from when the parts were manufactured?
That depends on when the final product or equipment is or was placed on the European Union (EU) market for sale or distribution.
If the parts are already incorporated into products placed on the market, the declaration of compliance needs to be based on the regulations as of the date they were placed on the market. If they have not yet been placed on the market, new documentation (based on the current regulation standards) is necessary once the products are placed on the market.
Article is accurate as of 2019-12-06.