RoHS Submission Response

The National Measurement Office (NMO) market surveillance authority is responsible for enforcing The Restriction of the Use of Certain Hazardous Substances inElectrical and Electronic Equipment (RoHS) Regulations 2012 (Statutory Instrument 2012 No. 3032) within the UK:

This Submission Response relates to a statutory request for information, made under Regulation 21 of the RoHS Regulations.

The form details the information required for the preliminary assessment of your organisation’s product compliance. Use of this document is optional. However, any alternative methods should contain at least the detail, type and level of information required below.

All information and supporting documents provided must be in English and in a form readily readable by the Authority.

In addition to the questions asked throughout this form additional documentation (outlined in sections 5 and 7) may also be required.

Reference Number:(provided on original request for information letter)
Registered Company Name:
Registered Company Address:
Section 1.
Please provide a positive declaration, signed by an authorised representative of the organisation, if your organisation is not involved in themanufacture, importation or distribution of regulated products as defined by the RoHS Regulations 2012.
No further information will be required at this time and we thank you for your co-operation.
Signed…………………………………………………. Position……………………………
Contact Details
Contact Person:(for all further communication)
Position:
Telephone:
E-mail:
Address:(if different from registered company address)
Company Website:
Does this person have Authority to speak on behalf of the organisation?
Section 2.
Please give an overview of your organisation: (E.g. please describe the size of your organisation (staff, approximate turnover, geographical location(s) etc.), whether you are an importer or OEM or if yousupply to end users or distributors etc.)

Section 3.
Using the following definitions taken from the RoHS Regulations please indicate whether you are a:
‘Manufacturer’ defined as “any natural or legal person who manufactures an EEE or who has an EEE designed or manufactured and markets it under his name or trademark”
‘Authorised representative’ defined as “any natural or legal person established within the Union who has received a written mandate from a manufacturer to act on his behalf in relation to specified tasks”
‘Importer’ defined as “any natural or legal person established within the Union, who places an EEE from a third country on the Union market”
‘Distributor’ defined as “any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes an EEE available on the market”
If you have indicated that you are a ‘manufacturer’ please complete sections4, 5, 7, 8 and 9
If you have indicated that you are an ‘authorised representative’ please complete sections4, 5, 7,8 and 9
If you have indicated that you are an ‘importer’ please complete sections4, 6, 7,8 and 9
If you have indicated that you are a ‘distributor’ please completes section 4, 8 and 9
If you fulfil more than one role please provide information under each of the relevant sections for each of your obligations.
Section 4.
What internal control processes do youcarry out in order to ensure compliance with the RoHS Regulations, in particular with regard to regulations 19, 20, 25, 26 and 30?
This may include but is not limited to:
  • A register of EEE placed on the market and/or recalledPolicies, procedures and corrective measures to ensure that non-compliant goods are not placed on the market
  • Communication channels with distributors, importers, manufacturers, market surveillance authorities and other competent national authorities in which the EEE was made available
  • Other systems or records in use to control compliance
We ask that copies of such systems and processes are provided.
Section 5.
Technical documentation
Regulation 21 (1a) of the RoHS Regulations (Statutory Instrument 2012. No. 3032) state that “The market surveillance authority may, during the period of 10 years from the day onwhich EEE was placed on the market, request the manufacturer who placed EEE on the markettoprovide it within such period as the authority may specify with all the information anddocumentation necessary to demonstrate that the provisions of these Regulations havebeen complied with in relation to the EEE.”
Technical documentation, established by the manufacturer, should be made available to the market surveillance authorityupon request.
The documentation shall make it possible to assess the product's conformity to the relevant requirements, and shall include an adequate analysis and assessment of the risk(s).
The technical documentation shall specify the applicable requirements and cover, as far as relevant for the assessment, the design, manufacture and operation of the product.
The technical documentation shall, wherever applicable,contain at least the following elements:
  • A general description of the product
  • Conceptual design and manufacturing drawings and schemes of components, sub-assemblies, circuits, etc.
  • Descriptions and explanations necessary for the understanding of those drawings and schemes and the operation of the product
  • A list of the harmonised standards and/or other relevant technical specifications the references of which have been published in the Official Journal of the European Union, applied in full or in part, and descriptions of the solutions adopted to meet the essential requirements of the legislative instrument where those harmonised standards have not been applied. In the event of partly applied harmonised standards, the technical documentation shall specify the parts which have been applied
  • Results of design calculations made, examinations carried out, etc.,
  • Test reports.
Please state below which technical documentation (relevant to the specified product) is supplied with this submission response.
Section 6.
Please provide the following information with regard to the product specified in the Request for Information letter:
  • Manufacturer contact information
  • Evidence the process by which you can access the technical documentation as specified in regulation 27 (1b)

Section 7.
Declaration of Conformity
Please provide a copy of the specified product’s Declaration of Conformity. If you are unable to supply the Declaration of Conformity please state below why.
Section 8.
The NMO are also responsible for the Batteries and Accumulators (Placing on the Market) regulations.
The Batteries and Accumulators (Placing on the Market) Regulations 2008 aim to control the use of mercury and cadmium in batteries. It also states that batteries must be marked appropriately and that they can be readily removed from appliances for end of life disposal. The Regulations apply to all types of batteries and those placing them on the market.
In order to avoid the potential for further engagement and to reduce burden to business the following questions are asked:
  • Are any of your products supplied with a Battery?
  • Do you sell/supply Batteries?
If so, please give an overview of the compliance systems you maintain to ensure compliant batteries and appliances are only placed on the market as required by the Batteries and Accumulators (Placing on the Market) Regulations 2008.
If you do not wish to answer at this time please explain why.
For Further information, please see our website:

Section 9.
Statement of Disclosure:
Please provide a statement in your own words relating to the accuracy and completeness of the information provided.
This section must be signed by a person with the authority to take responsibility on behalf of the organisation.
Signed: / Date:
Print Name:
Position within organisation:

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