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Contract manufacturers supply assembled products that can have a very large BOM parts list which can contain part numbers from a large number of suppliers. EU contract manufacturers have a legal obligation to comply with REACH and all contract manufacturers have contractual obligations to comply with RoHS, REACH etc when they supply they assembled product to the OEM customer.

BOMcheck is designed to cascade down the supply chain and so contract manufacturers should ask their suppliers to join BOMcheck and make declarations for their supplier part numbers. The contract manufacturer (CM) can then load their BOM parts list into BOMcheck to create an Assembly for the CM assembled product number. BOMcheck will calculate the compliance of the CM assembled product number by using the compliance declarations for the supplier part numbers.

It may take some time for the contract manufacturer’s suppliers to join BOMcheck. In the mean time, contract manufacturers can start by making a Regulatory Compliance Declaration (RCD) for the CM assembled product number by following the 5 step approach below. When the suppliers have made declarations in BOMcheck, the contract manufacturer can replace this RCD by loading their BOM parts list into BOMcheck to create an Assembly for the CM assembled product number. BOMcheck will calculate a new RCD for the Assembly and this will automatically replace the old RCD that the contract manufacturer made for the assembled product number.

Step 1: Focus on relevant parts in the assembled product

REACH Article 33 requires you to declare if the assembled product contains > 0.1% w/w of any of the REACH Candidate List substances. The 0.1% threshold for any of the Candidate List substances applies to the weight of the assembled product, so you should focus attention on the heavier parts which represent > 0.1% of the assembled product weight. The RoHS restrictions apply to every homogenous material in every individual part.

Step 2: Use the BOMcheck guidance to identify materials in the assembled product that do not have a compliance risk

The BOMcheck guidance tells you what types of materials could contain restricted or declarable substances. If the assembled product does not contain these types of materials then you can claim compliance for your assembled product. For example, the BOMcheck guidance highlights a number of substances which are used as plasticisers and flame retardants in certain types of materials. If your assembled product does not contain any materials that include plasticisers or flame retardants then you can claim compliance to the restrictions and declaration requirements for these substances when you make your RCD for the assembled product number.  

Step 3: Ask your materials expert about materials in the assembled product that could have a compliance risk

If your assembled product does contain materials which could represent a compliance risk, then ask your materials expert to review the guidance in BOMcheck to identify whether restricted or declarable substances could be present. For example, the BOMcheck guidance explains that certain phthalates (BBP, DBP, DEHP, DIBP) are used as plasticisers, particularly in PVC. If your assembled product contains parts that include PVC then you should ask your materials expert to identify what plasticisers are used in the PVC so that you can make your RCD for the assembled product number.

Step 4: Ask your supplier about materials in the assembled product that could have a compliance risk

If your assembled product does contain materials which could represent a compliance risk and your materials expert does not know what substances are included in these materials then you should ask your supplier. Following the example above, if the supplier’s part contains PVC then you should ask your supplier to identify what plasticisers are used in the PVC. You should attach the statement from the supplier to the RCD that you make for the assembled product number.    

Step 5: Sample testing for materials in the assembled product that could have a compliance risk

If the supplier’s part does contain materials which could represent a compliance risk and your supplier does not know what substances are included in these materials then you should consider sample testing. There are a number of certified testing laboratories that you can choose from. You should attach the test report to the RCD declaration that you make for the assembled product number.