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EU certifications

FredC

Diamond
Joined
Oct 29, 2010
Location
Dewees Texas
I have sold a few parts to a company in California and now they are requesting certifications for the EU:

I'm acquiring REACH (191 SVHC) and RoHS3 (2015/863) certificates on behalf of "company name"
The fellow sent me this when I asked what kind of certificates:


On the certifications:

REACH - Understanding REACH - ECHA

RoHS - Electrical and electronic waste - Environment - European Commission


I am a small shop with just a couple of employees with customers asking for Dodd-Frank conflict mineral certs required by US companies, now US customers are asking for EU certifications for products sold in this country?!?! Seems like the goal here is to eliminate small businesses.
I sent him this email, I do not know if it will pass for a certificate or he will email me an actual form.

Hello Tom,
I searched the reach site for info on the form 191 SVHC and nothing was found.
These items are all made from PEEK plastic purchased locally. We use less than 100LBS a year of raw material, after machining total products sold will weigh a few pounds.
Part numbers here

Looking over the REACH info regulation of materials involves the use of more than 1 ton and as far as I can tell PEEK is not a dangerous material.
Our (Part numbers here) use 2024 aluminum, 304 stainless steel, 416 stainless steel, PEEK plastic, and a very small quantity of stainless spring steel. As far as I know none of these are regulated and none are purchased in quantities of any where near 1 ton per year.

XXXX is purchased in weights ounces per year. The material is described as ultra pure rubber containing no bromides, fluoride, chloride, sulphate, sodium or silicon.

Many references were made to the number 863 but none to 2015/863 on the RoHS site.

Perhaps you can supply the forms you need perhaps I can fill them them out if this explanation can is not sufficient.
Best regards,
Fred


Is everyone else dealing with this kind of requirements? How do you do it?
 
Well here is the reply to my email. Evidentially certification is a process not just a form to fill out. A whole month to get certified?!? Man I got other things to do, like make parts! Tom Must be working for a third party and not the customer.


Hello Fred,

Unfortunately, it’s ultimately up to you and your company to decide whether or not to pursue certification. I can’t give you any instruction on how to accomplish this because I don’t have the information and am not qualified to do so. I do know that most companies that don’t already have certificates tend to take about a month to acquire them. Sorry I can’t help you more!

That said, if certification is something you decide (or not) to pursue, please let me know!



Thank you,

Tom

The third party for the Dodd Frank conflict minerals is very insistent, required soft ware to fill out the forms that I did not have would not accept a printed out form mailed to them. Year after year, I was hoping this year the requirement to fill it out would be over but here it is again.
 
Unless you were buying minerals[in my 15 second search], I cannot see how Dodd Frank affects you, I had never even heard of it, WRT conflict minerals.

ROHS used to be mostly lead content

you could probably get ROHS certs I would guess from material vendors


I don't deal with companies that ask for this stuff so..........basically if companies are asking for such things with no warning, they must be huge or just jerks
 
Conflict mineral certification is technically required if you buy one tungsten carbide insert. The company this third party is working for is a good customer but it is a pain dealing with their third party.

I just did some research on the EU deal and the customer that this other third party represents has not bought from us in 4 years. I just called them and they looked up what they got from us and said it did not apply any way. GRR!
I could have been working all morning instead.
 
Certification is done by a 3rd party and only applies if you are selling your products into Europe.

If you are a supplier, a declaration of conformance should be all you need. I have done these for both REACH and RoHS at the customer's request.

This is just the customer keeping their paperwork in order, no need to make a fuss over it. Just give them a declaration on a company letterhead and go on with whatever you were doing...
 
First the EU issue is settled.

Here is the email text from third party hired by my customer:
Dear Valued Supplier,

Name removed

The United States Conflict Minerals Rule requires companies to provide a report to the U.S. Securities and Exchange Commission (SEC) on the due diligence processes in place to determine conflict mineral sources. Companies must also disclose the chain of custody used to avoid obtaining four specific minerals from countries adjacent to and including the Democratic Republic of the Congo (DRC) that are known to finance or benefit armed groups (Legal Reference Dodd-Frank Act).



As part of this compliance process, companies survey their supply chain to disclose whether their products contain tin, tungsten, tantalum or gold, regardless of where they are sourced from. As the agent of (customer's name removed), acting on (Customer's name removed) behalf, Assent Compliance is authorized by (Customers name removed)to collect this important conflict mineral information (link to letter ). As a supplier for (Customer's name removed), we request that you complete the standard report, called a Conflict Minerals Reporting Template (CMRT) v5.11, applicable for 2018.



We request a completed CMRT no later than three weeks from today.



If you are ready with your CMRT, follow the link here:


Launch Portal



If you do not use any of the covered minerals in your products, filling out the company information and answering ‘No’ to Question 1 on the declaration tab will complete the CMRT form and require no additional information to be provided.



If you require further assistance, or have any questions regarding this request, the CMRT or the online portal, please contact [email protected] or speak to our live support chat available through the Supplier Portal. You can also visit our Assent University for helpful training resources and additional information.



Thank you,



Assent Compliance Inc. | Assent Compliance
[email protected]

Looks to me like if I want to keep this customer I need to fill out the form and the way I read it whether I use any carbide or not. If none of the minerals are used in our processes I get to quit at line #1. Seems like one carbide insert or end mill and I get to fill out the rest of the form. In years past I they would not give me an address to send a completed printed form, I have not downloaded the form this year to see if it is different.


Gustafson, tell me if I am wrong.
 
First the EU issue is settled.

Here is the email text from third party hired by my customer:
Dear Valued Supplier,

Name removed

The United States Conflict Minerals Rule requires companies to provide a report to the U.S. Securities and Exchange Commission (SEC) on the due diligence processes in place to determine conflict mineral sources. Companies must also disclose the chain of custody used to avoid obtaining four specific minerals from countries adjacent to and including the Democratic Republic of the Congo (DRC) that are known to finance or benefit armed groups (Legal Reference Dodd-Frank Act).



As part of this compliance process, companies survey their supply chain to disclose whether their products contain tin, tungsten, tantalum or gold, regardless of where they are sourced from. As the agent of (customer's name removed), acting on (Customer's name removed) behalf, Assent Compliance is authorized by (Customers name removed)to collect this important conflict mineral information (link to letter ). As a supplier for (Customer's name removed), we request that you complete the standard report, called a Conflict Minerals Reporting Template (CMRT) v5.11, applicable for 2018.



We request a completed CMRT no later than three weeks from today.



If you are ready with your CMRT, follow the link here:


Launch Portal



If you do not use any of the covered minerals in your products, filling out the company information and answering ‘No’ to Question 1 on the declaration tab will complete the CMRT form and require no additional information to be provided.



If you require further assistance, or have any questions regarding this request, the CMRT or the online portal, please contact [email protected] or speak to our live support chat available through the Supplier Portal. You can also visit our Assent University for helpful training resources and additional information.



Thank you,



Assent Compliance Inc. | Assent Compliance
[email protected]

Looks to me like if I want to keep this customer I need to fill out the form The way I read it I have to fill it out whether I use any carbide or not. If not then I get to quit at line #1. Seems like one carbide insert or end mill and I get to fill out the rest of the form. In years past I they would not give me an address to send a completed printed form, I have not downloaded the form this year to see if it is different.


Gustafson tell me if I am wrong.

I have no idea

but you are not buying any of the above mentioned minerals, your products do not contain them. Inserts are not tungsten, they are tungsten carbide.

I would check the box and never think about it again.
 
...As part of this compliance process, companies survey their supply chain to disclose whether their products contain tin, tungsten, tantalum or gold, regardless of where they are sourced from.


Looks to me like if I want to keep this customer I need to fill out the form The way I read it I have to fill it out whether I use any carbide or not. If not then I get to quit at line #1. Seems like one carbide insert or end mill and I get to fill out the rest of the form.
I do not think using carbide inserts in your process is something you have to report.

It's only if your products contain tungsten that would matter.

Quit at line 1.
 
SEC suspends conflict mineral rule enforcement
| Supply Chain Dive


dunno if this means anything


LEt's walk through this a little.

Do you buy gold

No

do you have a smart phone?

well, you bought gold

do you have a computer

ditto



If there is any sense in this regulation[certainly debatable] it is going after the people who are buying raw materials

If the Congo was producing conflict bauxite, then maybe it would make sense for you to track your supply chain of aluminum.

But really, Yarde is the one who could track it, not you, so certs should be available from them


Has anyone here had to fill this stuff out?


I have never heard of it.
 
Gustafson,
I looked at your link and technically this may be dead but the customer is still requiring it as part of their "due diligence" I guess. I talked to the assent compliance rep and she said even using it in the process was sufficient to have to fill out the rest of the form. This time including each source of carbide with a list of mines each one sourced their tungsten from.
I am looking to see where it says "used in the process but not contained in the product" and can not find it now.

Glad I do not sell anything with tin/bronze in it anymore. The products I silver soldered do not have any tin in them either I think.

Since due diligence and political correctness are such a thing today I asked the Assent rep if she or anyone in their organization has sexually harassed anyone and would they provide a certification to that fact. If not maybe I should not do any business with them.
 
Gustafson,
I looked at your link and technically this may be dead but the customer is still requiring it as part of their "due diligence" I guess. I talked to the assent compliance rep and she said even using it in the process was sufficient to have to fill out the rest of the form. This time including each source of carbide with a list of mines each one sourced their tungsten from.
I am looking to see where it says "used in the process but not contained in the product" and can not find it now.

Glad I do not sell anything with tin/bronze in it anymore. The products I silver soldered do not have any tin in them either I think.

Since due diligence and political correctness are such a thing today I asked the Assent rep if she or anyone in their organization has sexually harassed anyone and would they provide a certification to that fact. If not maybe I should not do any business with them.

Yeah, no

not even going to try

I'm checking the box and moving on

I think you have put more thought into it than I ever would

Similar to my iphone example, and your harassment example, it is ridiculous.

You are not buying these materials and the people who do, their compliance departments can worry about it

Oh, and by the way, I do not tell customers all my sources any more than I send them copies of my CNC code
 
Since due diligence and political correctness are such a thing today I asked the Assent rep if she or anyone in their organization has sexually harassed anyone and would they provide a certification to that fact. If not maybe I should not do any business with them.

There NEEDS to be "push back" or the parasites will (try to) inherit the very Earth.

"In house" example: C&W's US-domestic entity had decided they could "maybe" find a market for DS1 data circuits, offered a pilot service as a trial.

A determined, but very officious clerk kept calling and hammering me that we were not ALLOWED to implement those circuits because her department did not yet have the full documentation, plus review and approval, as to how it was to be provisioned and serviced.

Bluntly, I told her that I had personally installed one, her Director of Network Engineering another one out of the first - and only - three. No two were alike, and WE not SHE would decide what we wanted to document if/as/when we had better sight of which direction it was going or where WE chose to steer it - if even we chose to continue the service AT ALL.

Not good enough. She goes to said Director - her next-higher, two levels up to get told the same thing.

STFU. We'll TELL you when we are good and ready. Meanwhile, a DS1 is a DS1, we are satisfying a real-world, not "paperwork" customer and getting PAID for that.

Which IS what "the game" is all about, yah?

"Winning" by satisfying a need. "Scored" by earning a crust for it. "On the field of battle", so to speak.

Not by generating jobs for third-party scorekeepers. See Health Scare "industry". More paper-pushers than Medics, long-since.
 
I did some more reading on the definitions and found my "out". The form is such that I can not copy and paste so I typed it out (there may be typos)

I found this in definitions on line 17
"Necessary for the production of a product"
A conflict mineral will be considered to be necessary to the process when: 1) it is intentionally included in the product's production process, other than if it is included in a tool, machine, or equipment used to produce the product (such as computers or power lines)"

Too bad for you guys making bronze bearings!

Barbter and Gustafson thanks for asking enough questions that I found this.

I printed out the form to answer section 1 NO and I see why I thought I had to fill out the rest, it says: " -- or in the production process". If I did not find that thing in the definitions I would still be doing this.
 








 
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