Products must be designed and manufactured using restricted substance controls (RSC) that ensure compliance to regulatory and customer requirements. Sources of non-compliance are still being found in many electronic products and within the supply chain. It is cost prohibitive to test every homogeneous material for restricted substances. As such, each organization must find a balance of supplier information, manufacturing and assembly controls, and analytical testing that is effective and cost efficient. Supplier information and manufacturing processes must be assessed for risk of non-compliance or contamination.

An organization’s Restricted Substance Controls should address key elements based on it’s business model, supply chain risk, and operations:

• Design for Compliance
• Supply chain compliance risk assessment
• Procurement and Out-sourcing
• Manufacturing and Assembly Operations
• Use of restricted substance under exemption
• Inventory Management
• Repair and Return Operations
• Management Responsibility and Authority
• Monitoring, Measurement, Analysis, and Improvement

Restricted substance controls should be documented within the Conformity Assurance System.

For support on defining and implementing Restricted Substance Controls, contact ECD Compliance.