Product Compliance: Information for Obsolete Parts

Question: My company sometimes buys specific parts from brokers, especially when the parts are no longer manufactured and are difficult to find through our standard distributors. These brokers are generally unhelpful when we send them informational requests for the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation, the EU RoHS Directive, and Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65) compliance. Their explanation is that the parts we purchase from them have often not been produced for several years, so no up-to-date compliance information exists.

How should we handle these cases? Is testing necessary? Should we be requesting this information at all if the parts are obsolete?

Answer: Your company should continue requesting compliance information on obsolete parts. If the supplier or manufacturer has full composition data, they may be able to use this to provide updated compliance information. If the supplier or manufacturer is unable to evaluate composition information, ideally they would do their own testing or risk assessment to support a request from their customer (you). If they also refuse to do this, it’s up to you to perform risk assessment and/or testing. As always, ensure this process is carefully considered and documented. Compliance determination is especially important for obsolete parts, particularly if a part is crucial for existing or future products.

Article is current as of 2020-06-12.

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