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July 1 has come and gone. RoHS has kicked off in Europe. Are you ready? And how do you prove it to your customers?

There's certainly plenty of confusion among manufacturers and suppliers as to which way to go, or where to start. For its part, the European Union has clarified - somewhat - its stance, issuing in May its official enforcement document for RoHS-compliant product.

As expected, the new document, RoHS Enforcement Guidance Document, calls for the use of XRF testing as the screening mechanism.

Despite that, the standard says that companies will be assumed to be in compliance, and that the primary means of enforcement will be a company's own statements to that effect. In a section titled Compliance Documentation, the EU enforcement document reads, "While the overall approach to RoHS compliance is based on a Presumption of Conformity, it is recognized that national authorities will require self-declaration from producers as the key principle underlying the enforcement process."*

Self-declaration. This sounds strikingly similar to the philosophy of the ISO 9000 quality management standard.

But is self-declaration enough? The short answer is no. As Tom Rainone, president of Contract Manufacturing Services (cms-rohs.com), points out, "Most important, I think, is the requirement for a Compliance Assurance System to be in place at the producer. The RoHS Enforcement Guidance Document calls for a 'formally defined process which implements the requirements of the system and is integrated within the organization's quality and management systems.' "

In October 2005 in this space I examined the then-new EIA/ECCB-954 standard for products that are free of hazardous substances. As you might recall, EIA/ECCB-954 identifies procurement routes, traceability, handling and corrective actions for electronics designers and manufacturers. It closely resembles ISO 9000, on which it was based.

The standard has since been adopted by ISO's quality assessment branch, the IECQ (iecq.org), and renamed QC 080000, "IEC Quality Assessment System for Electronic Components (IECQ) - Electrical and Electronic Components and Products - Hazardous Substance Process Management System Requirements (HSPM)."

According to the Enforcement standard, companies must have an RoHS system in place. This creates some confusion among users, however.

The National Standards Authority of Ireland (nsai.com), one of the few registrars for the HSPM standard, sponsors a workshop on understanding and interpreting the document. One widely asked question among participants, says Lisa Greenleaf, U.S. operations manager for NSAI: If a company is not ISO certified, would they have to become certified to become HSPM? The answer is no, she says. "They have to be ISO compliant," a designation for firms that have built internal ISO systems and have been audited but have not registered.

However, it is to a company's advantage to have ISO 9000 under its belt. These companies will have a huge leg up on becoming HSPM compliant as well, Greenleaf says. And the HSPM audit includes verification of the ISO Quality Management System. "The standard itself is truly an overlay - the paragraphs line up perfectly," Greenleaf says. "It is just taking your existing system and making it more robust. Companies do not have to build a new system."

Where does the IPC-1752 standard for materials declaration fit into this? That standard, really a spreadsheet for material tracking, would be used as part of the HSPM system, much in the way that IPC-A-610 might be used to gain compliance with ISO 9000.

Surprisingly, as of April, just 14 companies had been registered to the HSPM standard. However, the movement is clearly growing, says IECQ chairman David W. Smith. He believes that HSPM will become the standard for RoHS compliance, much in the way ISO is the standard for process documentation.

* The RoHS Directive defines a "producer" as any person who a) manufactures and sells electrical and electronic equipment under his own brand; b) resells under his own brand equipment produced by other suppliers, (but for these purposes a reseller shall not be regarded as the producer if the brand of the producer appears on the equipment, as provided for in [a]); or c) imports or exports electrical and electronic equipment on a professional basis into a Member State.

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