Identifying Non-Compliant Item Specifications

The first step in assuring compliance will be to identify the non-compliant product that you currently specify. Luckily, the vast majority of materials commonly used to make the fasteners and related assembly components that we distribute are compliant with the directive. Only a few materials are non-compliant.

Plating presents a greater challenge. Any zinc plated parts you use will be the largest share of non-compliant product because hexavalent chromium is a component of the standard finish currently used in the zinc plating process. Other, less frequently used finishes may also be non-compliant including cadmium, iridite, alodine 1200, hot dip tin and electro tin solder 60/40.

If you currently specify any parts that call out non-compliant materials or finishes, you will need to make a change to be in compliance with the directive. Fortunately, there are viable alternatives.

Changing Non-Compliant Item Specifications

Your choice is pretty simple: change the material or change the finish. Which ever alternative you choose, try to pick a replacement that is commonly available to ensure continuity of supply. We will be pleased to provide guidance in this regard.

Materials that are compliant with the directive to the best of our knowledge include stainless steel, alloy steel, brass, some kind of aluminum and nylon. Switching to stainless will be the easiest fix in many cases. Most commercial standard steel zinc plated fasteners are also widely available in stainless steel; plus, stainless and non-ferrous or plastic materials are naturally corrosion resistant without plating.

Finishes that are compliant with the directive to the best of our knowledge include zinc with trivalent chromate finish, nickel and black oxide. Be aware that added cost and lead time to strip and replate will likely apply if you choose an alternate finish for a commercial fastener. The fastener supply chain is just beginning to adapt to the requirements of the EU directive and hexavalent finished zinc is still the standard finish for steel fasteners in the US. Trivalent zinc will become more commonly stocked by manufacturers, master distributors and importers, but it isn’t yet. Domestic electronic assembly component manufacturers have more quickly responded and most have or will shortly change their non-compliant zinc and other finishes to compliant varieties.

Also, your prints for zinc plated items may not specify the nature of the chromate finish. Please, if RoHS compliance is necessary for you, and you choose to keep using zinc plated items, change the prints and the descriptions so your buyers can easily specify and order trivalent chromate finished materials.

Unfortunately, there is no universal fix for all users, and you will need to evaluate the suitability of any change you make for your own application. Considerations include mechanical characteristics, torque values, appearance, expense and availability. We can provide you with specifications and samples, as well as cost and lead time information, at your request to help you in your evaluation process.

Quoting and Ordering Compliant Product

Once you have changed the specifications for your non-compliant items, it will be important for you to clearly specify the compliant features of the replacement items at time of quote, and again at time of order. For instance, if you now call out “steel zinc plated” you should revise your description to “steel trivalent zinc plated.” If you don’t we may not know you need the RoHS compliant material. A blanket “RoHS compliant materials required” statement on all RFQs and POs is also a good idea.

Our standard certification of conformance says, “The parts contained in this shipment meet applicable drawings or specifications designated on the purchase order.” Specify RoHS compliant goods, and our certification of conformance applies to the RoHS compliance as well as the other features of your items. If you need additional assurance, like manufacturer certifications or testing, please say so at time of quote and time of order. We can get them for you for an added cost.

The transition to compliance with the EU RoHS directive will be challenging and time consuming; but, ultimately, the effort to prevent hazardous materials from getting into the ground water of Europe will be worth it. Count on us to help you through the change.