RoHS/REACH Questions Answered by TÜV Rheinland Experts, Part 3

EN 50581 is the technical documentation requirement under RoHS and defines what must be contained in the technical file under RoHS.

Under sec 4.3.1, you have four tasks:

• Determine information needed
• Collect information
• Evaluate that information with respect to quality and trustworthiness
• Ensure the tech documentation remains valid (i.e. an eight-year-old declaration won’t cut it)

Essentially, the technical documentation must contain a general description of the product, documents for the materials, parts, or subassemblies, and information showing the relationship between the documents you have and the parts placed in the product. Companies will also need to list any harmonized standards.

Some of the materials used for evaluation or quantifying your due diligence for compliance are supplier declarations or contractual agreements, material declarations, and analytical test results. Essentially you need to compile all this information and collect supplier declarations. However, if there is any error, risk or apprehension involved, analytical testing should be done.

EN 50581 gives the framework and details on what to gather for technical documentation, how to evaluate and risk-rank it, and how to keep it current and up-to-date to make sure it’s still in line, as exemptions do have a tendency to expire.

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