IECQ常見問題問與答 - 立雍科技實業有限公司｜膠合棧板｜護角紙｜紙棧板｜木棧板

1.Some companies believe that as long as a test report shows the content of heavy metals such as lead, cadmium, mercury, and hexavalent compounds, it can be used to determine the RoHS compliance of materials. For example, some companies use test reports collected regarding the European EN71-3 toy safety standard to determine RoHS compliance. Is this acceptable?
Answer: No. EN71-3-9 specifies the "leaching amount" under certain environmental conditions, while RoHS specifies the "content" of materials. The sample preparation methods for the two tests are different, and the results may differ greatly. Test data cannot be substituted for each other.

2.The purchased parts contain multiple colors, but the test report only shows the content of hazardous substances in one color. Can such a report be used to determine the RoHS compliance of materials?
Answer: No.

3. If only one test result for a single homogeneous material in a component is available, can it be used to determine the RoHS compliance of the entire component?
Answer: No. It can only prove that this one product is compliant.
4.For processes that may involve contamination, switching cleaning methods are often used to prevent cross-contamination, but their effectiveness is difficult to verify. What are some reference suggestions (or experiences) for practice?
Answer: The cleaning and verification methods should be determined based on the degree of contamination risk. Evidence of cleaning capability can be considered from several aspects:

If only granular HSF and HS products are being replaced, it is sufficient to monitor with the naked eye to ensure that the clean areas (machines, sites, and packaging, etc.) are cleaned, and then have a designated person inspect and confirm (special process requirements).
If a chemical cleaning method is used, a preliminary verification should be conducted before implementation (e.g., whether improper cleaning may cause contamination, etc.), and the subsequent method is the same as before.
If dust contamination occurs during the cleaning process, dust prevention measures are required, and subsequent measures are the same as before.

5. For factories that have completed the RoHS switchover, all products must meet RoHS requirements. In this case, is labeling a key control item?
Answer:

標準中對於標識（7.5.3）的要求有4條
- 適當時，組織應在產品實現過程中採用合適的方法標識HSF產品；
- 任何包含有害物質的過程都應進行唯一標識和隔離以避免污染HSF產品；
- 組織應針對產品的監視和測量要求標識HSF產品狀態；
- 當有追溯性要求時，組織應控制並記錄產品的唯一標識。
根據以上條款的要求，標識實現的目的有四個重點
- 能識別出產品的HSF狀態；
- 避免HS污染HSF產品；
- 識別出HSF產品受監視或測量的狀態；
- 做為實現追溯性的手段。
Methods of Labelling
There are many methods of labelling, but whether or not the above objectives are achieved is the basis for judging the effectiveness of an organization's labeling system. Typically, when a factory produces both HS and HSF products, labeling is a key focus of control. However, if a company fully produces HSF products, whether or not to label the products becomes less important. In fact, this idea merely limits the purpose of labeling to identifying the HSF status of the product while ignoring other objectives.

For companies that have fully implemented HSF product production, all materials that may come into contact with the product at each stage from raw materials to finished products have been verified. Their incoming material acceptance process ensures that materials entering the production stage meet HSF requirements. In this case, the HSF status of the product during product realization is already guaranteed by other processes, so additional HSF product labeling is not necessary; the company's HSF product implementation status itself is a form of labeling.

However, this is only one objective of the labeling requirements in the standard. According to the requirements of standard 7.1, the organization should also plan the verification, validation, monitoring, inspection, and testing activities required for HSF products. For these activities, determining the methods used to identify whether products have been verified, validated, monitored, and inspected as planned remains a key consideration for the organization.

6. How can I confirm that the materials provided by the supplier comply with RoHS requirements? Is it based solely on the test report?
Answer:

IECQ QC080000標準只是要求對來料進行驗證，同時又提到建立必要的檢驗和其它活動，以確保採購產品滿足詳細的HSF採購要求。從標準本身來看，它所要求的是一個結果，具體做法沒有規定。也就意味著是由公司自已決定的，這樣公司的做法就很多了。以下可能的幾種情況供參考：
- 有檢驗設備，按抽樣計劃進行抽樣檢驗；
- 沒有檢驗設備，公司只規定確認供應商提供的測試報告是否在有效期內（一年或半年，公司自己的規定）和來料是否有標識；
- 只要確認來料是否是HSF合格供應商和供應商是否有不使用承諾。
- 或者是以上三種情況的任合組合
  所以說，如果公司就是這樣規定的，那麼單憑檢驗報告是可以的。
It must be made clear that ensuring that incoming materials comply with RoHS should be a series of actions, not just a single confirmation of incoming materials.
- The first step is to evaluate the supplier (including system management and implementation levels). Only when the supplier has a good management system can the occurrence of accidental events be avoided.
- Secondly, confirmation of sample approval should include test reports, non-use certificates, and liability commitments. This is because even with extensive testing, it's still only sampling, while the final product appears as individual units.
- The next step is change management. Companies typically use product declaration forms, which is a useful method. As long as the declaration form remains unchanged, it means the product status hasn't changed, meaning it's in the same state as when the product was approved.
- Finally, there is periodic sampling. The purpose of this is to verify the supplier's commitments, not to inspect the product itself, which differs from ISO 9001. The latter's inspection confirms issues exceeding limits, while QC confirms a situation where something is present or absent; if present, it generally indicates an exceedance of limits.

7. Some companies collect test reports not directly from their suppliers, but from their upstream suppliers. What risks does this pose in terms of hazardous substance management? How can it be controlled?

答：

The main risk in this situation is that the collected test reports may not accurately represent the content of hazardous substances in the raw materials used. Companies often neglect to further verify whether their materials are produced by their direct suppliers using raw materials from the supplier specified in the test report. While the RoHS Directive and the IECQ QC080000 standard do not require annual third-party testing reports, in practice, collecting test reports is still a relatively straightforward way for companies to assess and confirm compliance with regulations regarding the content of hazardous substances in their raw materials.
Systematic management is therefore more important. The purpose of implementing such a system is to ensure that the content of homogeneous substances and hazardous materials in products meets the standard requirements through supply chain management, rather than simply obtaining test reports. The ultimate goal of enterprises managing hazardous substances and establishing the IECQ-HSPM system is to ensure that the final product meets the requirements and reduce the risk of hazardous substances exceeding the limits.
有害物質過程管理的建議
- a.次級供應商指定，原料指定。應確認供應商的物料成分調查與聲明的信息，這些信息是否包括其上游供應商的情況，如供方名稱，材料名等，再核對其送料規格與聲明的信息的符合性（材料的一致性與變更管理）；
- b.變更管理（現在只是變更協議不是管理）；
- c.現場審核；
- d.不定期抽查（根據風險分析確定頻次決定抽查方案）；
- e.客戶送的試樣管理。