Hello Peter,
To be honest, I was hoping to see some replies to this question to see what others suggest or have done themselves. Hopefully, there were private replies to help you out. My thoughts…The problem is not just that the Declaration of Conformity is misleading, but your product is also mislabeled with the CE Mark. You do need to contact the regulatory bodies of those non-EU countries who expect CE Marked product. In your conversation with the regulatory bodies determine if they are concerned with RoHS compliance. In my experience with a similar issue, some countries were not concerned with RoHS, but wanted confirmation that the products were designed and manufactured within a quality system, that international standards were used, and that the manufacturers were audited by a Notified Body. You may be able to create declarations to international standards specifically for those countries that do not care about RoHS. The CE Mark, authorized rep, etc. would not appear on that declaration. You would have to remove the CE Mark from those installed devices so that they are not mislabeled. You should have a risk assessment that documents that the use of non-RoHS parts did not affect the safe and effective use of the product to help in your conversation with the regulatory body. Good luck.
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Christine Anderson
Senior Principal Specialist
Cleveland, OH USA
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Original Message:
Sent: 14-Jan-2019 20:12
From: Peter Gonzalez
Subject: EU RoHS - Focus on member states or all countries requiring CE marking???
Hello Friends,
I need some help, we are creating standard work for notifying EU authorities with a NonRoHS compliance placement occurs
The question on the table is, how does the industry handle RoHS noncompliance outside of EU for those countries that require CE marking
If products contain Declaration of Conformity that claims compliance with EU RoHS and the product is found to not comply, should we only focus on the member states for RoHS, or rework all products in countries outside the EU that require CE marking
Thanks to all
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