Lauren, Thanks. I will read this faq carefully, but the faq is not law, law is the directive itself. At that moment I am answering before reading this faq.
I think, I know the answer for my previous question. When I've printed directive I assumed that only Annexes I, II and III are interested for me and I've not printed the rest. I assumed that what should be in DoC is as for EMC and other directives. Yesterday I found the ROHS2 Annex VI. So I know that DoC must contain the unique device number and allow for traceability (traceability was translated to Polish law as allowing EEE identification and allowing to recreate its history). So I have to issue the separate declaration for each device. If they wonted to allow to declare for "range of numbers" they would certainly write it (as in EN 50581 they write "part" and "range of parts") wouldn't they ? This changes my point of view how the technical documentation must look like and I know that in EN 50581 "part" means "part" and not "part type". I understand that I have to collect declarations from suppliers of parts for that specific supplied parts (and not general declaration for part type) and than I can issue DoC for devices manufactured from those parts. Then whole game begins once more. So the ROHS2 concept is different than for EMC, LVD,.... where I can prepare technical documentation at the beginning and then produce in accordance with documentation. Here I can issue DoC only for devices I have declarations for parts used for their construction. I have never supposed that components are in scope of ROHS2 so the ROHS2 DoC (with device number) was needed for them. I understand that (if I trust the supplier) I need from him only (!!!) the declaration that this (supplied this time) specific range of parts are ROHS. For me the declaration send by supplier with parts is something simpler than signed contract. I understand that in EN 50581 4.3.3 (a) the second point: "- Signed contracts confirming that the _manufacturer's_specification_ for the maximum content of restricted substances in a material, part or sub-assembly is fulfilled." is there for the situation when manufacturer uses some exemptions form ROHS2 than he prepares specification for maximum content of .... and than signs with his supplier contract containing this specification. If I don't plan to use exemptions I think I should use the first point of 4.3.3 (a) (it is first as more common). So I need only declarations but unfortunately not declarations for this specific part type (which I could collect from manufacturers www pages) but for this specific range of parts (which I have to get from supplier). This sounds logic If you remember of traceability needed. My problem is - if the suppliers would like to send such declarations with each 100 pcs of resistors I will order. I can suppose ROHS declaration at each invoice, but that means I have to copy each invoice and make this copy a part of ROHS2 technical documentation. I have never seen invoices as part of documentation. Should I become used to it ? The need for such lot of papers (individual DoCs (copy of each for 10 years), endless growing documentation, and that all multiplied by the number of devices sold all over the Europe) looks for me as being in clear opposition to environment protection. They don't see it or they don't care of environment? As a designer in small company I see that all being in opposite to sentence from directive: "(8) Taking into account technical end economic feasibility, including for small and medium sized enterprises.... " Regards Piotr Galka P.S. Since I have started to analyse ROHS2 one sentence from cabaret describing our economy solutions (long time ago when Poland was a socialism country) continually comes to my mind: "If I wouldn't know that it is stupidity I could think it is sabotage." ----- Original Message ----- From: Crane, Lauren To: Piotr Galka ; EMC-PSTC@LISTSERV.IEEE.ORG Sent: Friday, November 15, 2013 2:22 AM Subject: RE: [PSES] EN 50581 part/range of parts Piotr, Reading the EU Commission's FAQ on RoHS2 might help you http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf. Components (i.e. things not intended for direct sale to the end user) are not considered to be in scope of RoHS (even though they fit the definition of EEE). It has to do with the concept of "finished product". So, if you are going to be using the 100pcs of resistors in your product, you should constrain your supplier with a contract that requires them to be RoHS compliant, but you do not need a DoC from them. Regards, Lauren Crane KLA-Tencor From: Piotr Galka [mailto:piotr.ga...@micromade.pl] Sent: Wednesday, November 13, 2013 8:27 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] EN 50581 part/range of parts To English language standard experts, How do you understand "specific part" and "specific range of parts" in last sentence in EN 50581:2012 Cl. 4.3.3 (a): "Such declarations ... shall cover a specific ... part ... or a specific range of ... parts..." According to: - directives understanding of putting product on the market (not type but single piece), - direct meaning of the words (as I fill them), it looks that: part = this one single part, range of parts = some (specified) number of the same type parts. If it is true I see problems with ROHS DoC. If I buy 100pcs of 0603 1k resistors should I ask the supplier for sending me the declaration for specified range of these 100pcs ? And the same for all 200 other types of elements ? The other way of understanding is: part = part type (resistor 0603 1k) range of parts = range of part types (resistor 0603 from 1ohm to 10Mohm) This looks more logical for someone trying to make ROHS DoC but: If they wonted to say "part type" or "range of part types" they would certainly said that. As they didn't said that I think they had the previous understanding in mind. What is the solution I don't see ? Best Regards Piotr Galka - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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