Question: My company contracts with a manufacturer to produce our products. The manufacturer purchases the raw materials (metal castings) from a foundry based on our specifications, then machines them to make our products. We’ve asked the manufacturer for data for several product compliance regulations, but they have told us that because they source their materials based on our specifications and don’t change the materials during the manufacturing process, they will not provide us with declarations. Is this correct?
Answer: Your manufacturer should be requesting information from the foundry and providing declarations to you for two reasons.
First, the specifications provided to manufacturers in cases like this often allow for significant variation. They may set performance or quality standards rather than material composition requirements, or may set requirements broadly enough that regulatory compliance status can’t be established without additional data. In some cases, multiple specifications may be used and the manufacturer is allowed to choose or switch between them. Specifications don’t automatically mean that a product’s material composition is predefined.
Second, information sharing in cases like this often depends on established commercial relationships. Since your manufacturer is purchasing the materials from the foundry, the foundry’s relationship is with them, as is the economic incentive for the foundry to provide the necessary information.
Article is current as of 2020-06-26.