And if asked to provide evidence, documents, etc backing up the declaration,
there will be a limited time to do so.
Management might take the position to get the doc's when asked, and hope that
they are indeed in compliance.
The consequence can be banned from the market for a period.
That happened due to a manufacturing defect and insufficient quality control to
detect the defect.
Near a year to correct and demonstrate compliance before getting off the ban.
So nothing moves into our distribution control without solid evidence of
compliance.
A letter from an importer does not suffice, but if often offered.
Even a big time manufacturer has offered to print anything we want on the label.
On Thursday, December 16, 2021, 3:30:12 PM EST, John Woodgate
<[email protected]> wrote:
My advice is always cite, because Mr. Militant Customs Man can challenge your
import because there is no proof on the DoC that you have taken all the
amendments into account. You don't need to list every amendment; 'and all
amendments up to the date of dispatch' should be enough.
======================================================================================
Best wishes John Woodgate OOO-Own Opinions Only
www.woodjohn.uk
Rayleigh, Essex UK
Istae nunc praetereunt nisi non ubicumque
On 2021-12-16 20:23, Charlie Blackham wrote:
Doug
It’s not required – the applicable Directive is still 2011/65/EU
2015/863 Directive amended it…….as did 60 or so Commission Delegated Directives
Whether you like it or not, declaring compliance to RoHS means that you are
declaring compliance with RoHS, as amended, with applicable permitted
exemptions if permitted, at the time of signing.
Lots of people like ask to see it on the DoC, so I agree that it won’t hurt,
probably isn’t “wrong”, but also is not “required”
You do not however declare compliance to RoHS III (it doesn’t exist)
Best regards
Charlie
Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247
From: John Woodgate <[email protected]>
Sent: 16 December 2021 20:19
To: [email protected]
Subject: Re: [PSES] RoHS III references on the DoC?
It can't hurt to cite it. There are cases where a citation is not allowed, but
I don't think this is one of them.
======================================================================================
Best wishes John Woodgate OOO-Own Opinions Only
www.woodjohn.uk
Rayleigh, Essex UK
Istae nunc praetereunt nisi non ubicumque
On 2021-12-16 19:48, Douglas E Powell wrote:
All,
Given that Directive 2011/65/EU has been amended by Directive (EU) 2015/863, is
it now necessary to reference the amendment on the Declaration of Conformity?
This is an amendment to Annex II, and "RoHS III" appears terminology used by
the unwashed masses.
Thoughts?
-Doug
Douglas E Powell
Laporte, Colorado USA
[email protected]
LinkedIn
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