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May 15, 2006

Since we build to customer spec are we safe from Material Declaration ...

We are a small CM and have started producing Lead Free circuit boards. We have taken the position that we will build boards to the customers BOM. Our customers BOM includes the LF P/N and the Mfr. We also supply a 'cert' with our shipments certifying that the product was built to the customers requirements.

Since we build exactly what the customer asks us to build are we safe from any Material Declaration problems? Does it meet any Due Diligence requirements?



B.W.

Experts Comments

Per the RoHS legislation, the CM is not responsible for ensuring compliance of the entire. This is the OEM's responsibility. You are only responsible for ensuring compliance of the solder/conductive adhesive, which can be done through cert sheets from these manufacturers or performing your own testing (if you are small, you'll probably do the former).

However, it sounds like you are uncertain if your customers are expecting you to be an active participant in ensuring RoHS compliance. Therefore, I would strongly recommend that you communicate your concerns to your clients and, when appropriate, point out that Pb-containing parts are on the BOM.

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Dr. Craig D. Hillman
CEO & Managing Partner
DfR Solutions
Dr. Hillman's specialties include best practices in Design for Reliability, strategies for transitioning to Pb-free, supplier qualification, passive component technology and printed board failure mechanisms.
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