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I emailed the supplier of an OLED panel that comes mounted on a PCB that contains the driver circuitry, and they claim the part is ROHS compliant. I will be using this component in a system that I need to be fully ROHS compliant for the European Union CE certification. Are there some documents that the supplier can provide to prove ROHS compliance? I am hesitant to simply take their word for it, as I imagine if they are lying, I will be liable.

sebastian323
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    Why didn't you just ask the manufacturer or supplier if they have documents? – DKNguyen Sep 13 '22 at 18:04
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    Proof is harder than a test. RoHS can often be spotted by it's less-mirror-like (and more aluminum-like) overall finish and white-ish flux residue. Contaminate one of the joints with lead solder; if it is shiny when molten but solidifies as dull grey (inter-metallics), then it was RoHS. RoHS is also generally harder and more brittle than lead; pick at it with a sharp blade. Lead is more "gummy." – rdtsc Sep 13 '22 at 18:24
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    The manufacturer should be able to provide a RoHS compliance certificate. Also, it's not just solder, there are other materials that have to be in compliance as well. – John D Sep 13 '22 at 18:34
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    Why do you have to prove it? If you're liable for lying, then surely they are also liable for lying, and if you get sued, you can then sue the supplier? I think that generally, manufacturers are *not* expected to test every component they receive from suppliers. – user253751 Sep 13 '22 at 18:38
  • What makes you think that anyone will ever check? You get your pile of datasheets from the component manufacturers, and file them away as your compliance evidence. You stamp "CE" on your product, and everybody is happy. – Simon B Sep 14 '22 at 19:09
  • @rdtsc You are referring just to soldering. RoHS is not limited to solder alloys, IIRC. All the components in the assembly or the module should be RoHS compliant. So it would be quite hard to assess whether or not some (say) chips are compliant, especially if their part number has been scraped off. – LorenzoDonati4Ukraine-OnStrike Sep 15 '22 at 09:48
  • @user253751 "Why do you have to prove it?": two words *due diligence*. In some jurisdictions you can be liable just for not having collected all the documentation that "proves" compliance. If you do collect them and someone checks and finds your product is not compliant you are still liable, but you can claim due diligence to reduce the amount of liability and "off-load" some of the responsibility up the supply chain. ... – LorenzoDonati4Ukraine-OnStrike Sep 15 '22 at 09:55
  • @user253751 ... Up to a point, of course: I'm quite sure you are not required to decapsulate chips and chemically analize them for traces of non RoHS materials, however if you buy your parts from shady middlemen known for bad business practices you could have a harder time claiming you didn't know. – LorenzoDonati4Ukraine-OnStrike Sep 15 '22 at 09:56
  • True @LorenzoDonatisupportUkraine. I'm assuming that if they didn't care about solder type, then they wouldn't care about component constituents either. Although lead-based components are harder to find these days. – rdtsc Sep 15 '22 at 12:07

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The datasheet of the component is sufficient proof. Or the component's own EC Declaration of Conformity, in case that applies. Save a copy of it as part of your RoHS documentation, it all goes into a technical file. If the datasheet doesn't say RoHS specifically, then don't use that part.

Note that "lead free" isn't enough, it must explicitly say RoHS.

Lundin
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