Oh, good question.
I confess, I am not intimately familiar with the content of the ROHS directives, however it is my understanding that with respect to "Lead-Free" compliance the two are no different.
So, my answer would be, No, you do not need to update any documentation.
Don't take this as gospel - it is just my understanding. I think a thorough examination of the EU's would be in order or at least a consultation with someone who knows the directives intimately.
Yes. You are correct. The 6 banned substances in ROHS 2 are the same list as ROHS I.
I'm just afraid there is a bureaucratic requirement in the documentation process.
Hopefully not. I will post anything I find out.
Well, the answer depends on what you mean by "RoHS 1" documentation. If it's just a bunch of certificates of compliance then yes, you'll have to do some work.
RoHS is now a CE Mark directive; it requires you to sign a Declaration of Conformity (article 13) and maintain technical documentation backing up the DoC. EN 50581, available now in final draft form (it has been approved and will be available in the next month or so), defines what is required. Basically, if you have reason to trust the data provided by your suppliers, you can take their word for it; if you can't, you need to get more information, control them better, and maybe even get test data to prove compliance. This all needs to be documented in your internal procedures.
So it's not just a matter of updating drawings; it's a matter of updating and rolling out changes to existing business processes, working with your compliance people to get them ready and willing to sign the DoC (which is the same piece of paper they already sign for safety and EMC; RoHS just gets added to it...or you can have a separate DoC), and working with your suppliers to make sure they're providing you the data you need and controlling their materials and processes.
There's an FAQ draft out for RoHS 2 now; you should read it:
Design Chain Associates, LLC
Sorry to be the bearer of bad news but yes "there is a bureaucratic requirement in the documentation process" and I've tried to generally describe it below.
Design Chain Associates, LLC
THanks for the great response. I know that ROHS will now be a CE mark directive and we have people working on all of that.
I was just curious (in my little world) - since "ROHS I" is officially going to be repealed 02 JANUARY 2013, do pbc fabrication drawings and
pcb assembly drawings for products going to EU member states need to state compliance with the new directive specifically (2011/65/EU)
or does compliance with 2002/95/EC roll into compliance without changing the actual documentation? It seems that the actual banned substance list
relating to pcb fab and assembly does not change in scope or quantities.That is a ton of drawings to touch, if so.
Thanks again for your comprehensive response!
Glad you found the info useful. There's no need to change drawings for PCBs or any other component to indicate compliance to this specific regulation (or with the previous version 2002/95/EC) - the directive does not require that. The only compliance indication required (or allowed!) is the CE Mark on the finished good (there are some minor exceptions that are addressed in the FAQ I mentioned above).