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If your products are subject to the European Union's RoHS Directive, you will need to collect specific RoHS compliance information from component makers on the many components in your BOMs for several reasons:

• to facilitate your RoHS-compliant manufacturing action plan
• to demonstrate that reasonable steps have been taken to ensure the products you have manufactured are RoHS-compliant

Despite the absence of clear guidelines from the European Commission many equipment producers have begun to implement their own policies and procedures for component documentation collection requirements. 

In an effort to simplify and standardize how the industry collects, tracks and discloses product material content information the IPC (Association Connecting Electronics Industries) published the IPC-1752 Materials Declaration Management Standard on March 9th, 2006.

IPC-1752 outlines a supply chain materials declaration format and process that provides a simple, effective approach to collecting, tracking and disclosing product material content information. The standard establishes electronic data formats and provides standardized forms to simplify the exchange of materials declaration information while improving efficiency and reducing costs

The forms, based on Adobe™ PDF forms technology, can be printed or can be exchanged via electronic means from e-mail to Web interfaces to advanced and secure business-to-business methods.

Data captured by these forms can also be extracted and exchanged in a standard XML format that will conform to the related RosettaNet Partner Interface Process® (PIPs).

Although a diverse group of both suppliers and manufacturers commented on the IPC standard its release has come after many end producers felt compelled to begin collecting data in their own methods and formats.  It is unclear at this time how widely the standard will be adopted but certainly provides a common platform that may help guide collection efforts going forward. 

Consider these steps when you are developing your RoHS Compliance Information Gathering Model:

1.  Create a multi-functional team to define, implement and review your plan.   Be sure to include colleagues from your engineering, manufacturing, procurement, quality, IT and legal departments.

2.  Design your plan to be sensitive to level of risk your company faces.   Consider the risks presented by your products, suppliers, and parts - if the risk for non-compliance is high, be sure your plan addresses all associated risks.

3.  Asssess your suppliers' and component makers' readiness to provide information.

4.  Consider your ability to use the data you request, including the ability to use the data throughout the rest of your business processes and IT infrastructure.

5.  Develop IT capability to store, maintain and report on the data you gather.

6.  Consider leveraging third-party data providers if your resources are limited.  Arrow offers several options to help you gather data.  Visit our Component Compliance Data pages for more information.

7.  Build in flexibility.  Focus now on gathering the data critical for compliance with RoHS, but make your plan flexible for any future developments in legislation or industry standards, such as the proposed IPC-1751 / IPC-1752 materials declaration standard formats.

8.  Be sure to document your approach to help show reasonable steps/due diligence steps taken.