RoHS Exemptions: Supplier vs. Manufacturer Responsibilities

Question: 

Under the Restriction of Hazardous Substances (RoHS) Directive, is it the responsibility of the part supplier or final product manufacturer to ensure exemptions are valid for a particular use case? 

Answer: 

Exemptions under the RoHS Directive are typically use-based, so it is up to the manufacturer of the final product to ensure that the exemption applies for their use case. However, many companies expect their suppliers to be compliant or eligible for an exemption, even if they do not know the final use of the part.

To meet these expectations, suppliers can include any exemptions in their declaration that would apply for the supplied part. If the supplier is unsure if a part is eligible for an exemption, it is acceptable to declare the part as non-compliant and allow the final manufacturer to apply for the exemption, if applicable. 

Article content is current as of 2019-12-20.

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