Dena Technologies has published our environmental policy and you may find it here or in the menu.
Some of our clients request us to declare their products are lead-free, conforming with RoHS legislation in Europe, California, China and other countries. A Certificate of Conformance is provided if requested, but products we make are lead-free and RoHS-Compliant by default unless either specifically requested or if any required component is non-compliant.
We do have a few clients that request their products to be made with leaded solder. These products may or may not be exempt from RoHS. In our position we do not have any authority or knowledge of the product application to determine whether this is the case or not. We give our clients the benefit of a doubt, but we cannot broadly declare with certainty that all of our products are compliant, even though we would prefer that to be the case.
Canada does not quite have regulations equivalent to RoHS or REACH which apply to the European Union, but some chemicals in those lists are regulated in Canada, such as mercury and PCB’s. Some other states and countries do have such regulations including California and China. There are exemptions for some applications, but it is outside of our scope to make determinations for each product that we are asked to build. We will gladly work with our clients to help them in affirming compliance with any regulations they require.
These regulations apply to pure chemicals, known in the regulations as “substances”. We don’t purchase any pure chemical substances. “Preparations” are chemicals made by combining other chemicals, such as solder or flux or cleaner which we do purchase. “Articles” are assemblies. Components such as resistors, IC’s, and PCB’s are “articles”. We do our best to purchase compliant components and chemicals.
Since we are not located in Europe, REACH doesn’t directly apply to us, but anyone trying to import products we have made into Europe may be expected to affirm compliance. At the present time (April 2018), distributors such as Digikey are not prepared to declare REACH compliance for each of the millions of components they sell. It would be unreasonable for us to go through every line item on every bill of materials to determine if each and every part is REACH compliant, unless our clients are willing to work with us in that effort.
Declarations like this are made to show our and our clients’ due diligence. It doesn’t mean we can guarantee these chemicals aren’t present. Only a chemical analysis would establish that.