Looking for a valid ROHS declaration for JGS516-200EUS

[rohs_issue]

Hello,

1. We are looking for ROHS declaration of the following Switch: JGS516-200EUS.
   The existing ROHS statement that we received last year from Netgear, includes non-Valid ROHS exemptions, therefore we can't deliver to EU.
   We need ROHS declaration, which is compliant with ROHS Directive 2011/65/EU and 2015/863 with Valid exemptions (or non-exemptions at all).
2. In case that Netgear cannot provide such declaration, please advise which is the equivalent switch, which can provide same functional solution and will have a valid ROHS declaration.

Thank you for the support,

Ido

[YeZ · Accepted solution]

You need the CoC file instead, attached.

You can email environment@netgear.com for any further RoHS related inquries.

Thank you.

Ye

[schumaku]

In my reading of EUR-Lex - 32015L0863 - EN - EUR-Lex (europa.eu) it's not "ROHS Directive 2011/65/EU and 2015/863". Much more it's a change of the amendment of Annex II to Directive 2011/65/EU - overall, it remains to be the ROHS Directive 2011/65/EU after the effective date. The 204-11385-01_CE_JGS516_JGS524_JGS524F_EN-EP-FR-IT-GR-SP_29JUN18.pdf (netgear.com) is signed in June 2018, so it's covering the 2015 amendment.

Please enlighten the interested reader where you have spotted the exemptions - valid or invalid ones. 

[rohs_issue]

Hi,

Thank you for the answer.

But the question came from a place, that NETGEAR already sent us in the past ROHS decleration for 2015/863. See attached file.

The problem is that one of the mentioned ROHS Exemptions in that declaration, is not valid today and we are blocked to deliver it to EU.

Therefore, my request, is to have Similar declreation, which includes VALID exemptions.

In order to simplify this:

Exemption 6A is not valid, but 6A-I is still valid.

So please check, we need to have declration with 6A-I or without 6 at all (since it will be expired on July 2021).

Please also note that 7C-I will be expired on July 2021 as well.

Waiting for your updates.

Thank you,

Ido

[schumaku]

Iso,
Please bei aware I'm not Netgear, just trying to re-enable the communication. Sent emails on the people in charge having signed the certs back then - and never heard anything.

Now we face a cert doc to my knowledge not available online, looking like a counterfeit with its patched product name, expired exceptions or expiring soon.

Can't understand why these changed and enhanced regulatory still has not made it in the printed and downloadables....

[rohs_issue]

Hi and Thanks for the response.

So what should be the next steps?

Who can answer and what are the recommendations?

Will we receive ROHS 2011/65/EU 2015/863 with Valid exemptions by Netgear?

Can Netgrear proposed for us an equvivalent product, that has valid ROHS decleration?

Need your professional advice on this.

Thank you.

Ido

[schumaku]

Ido,

Sorry for the name type in my previous post.

@YeZ can you please talk to the person in charge for the ceritifcation work please?

Regards

-Kurt

[DaneA]

@rohs_issue,

Kindly try to send an e-mail request to sales@netgear.com 

Regards,

DaneA

NETGEAR Community Team

[rohs_issue]

Hi DaneA,

Thank you very much.

I will try to send a mail to the mail address.

Thanks,

Ido

[schumaku]

Curious about the outcome. In fact, all the CoC referred above (for all models) require an update - explicitly listing the current as well as the status for earlier manufactured devices, including 

"Directive 2011/65/EU (the RoHS Directive) OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment” superseding “Directive 2002/95/EC (the RoHS Directive) OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 January 2003. The Certificate of Compliance includes Directive 2015/863 published in 2015 by the EU (often referred as RoHS 3) and Directive 2017/2102/EU published by the EU November 17, 2015.  

Based on the information provided by our supply lines, and our certain knowledge pertaining to our own processes, products supplied by Netgear are RoHS compliant for orders placed on or after the January 1, 2006. Products supplied on or after January 3, 2013 are also RoHS compliant according the Directive 2011/65/EU, Directive 2015/863 and Directive 2017/2102/EU from the moment the respected directive came into force.

The confirmation of compliance status by our supply lines is granted for products which do not contain any of the restricted substances referred to in Annex VI in the RoHS Directive 2011/65/EU & Directive 2015/863 with a higher than maximum concentration values tolerated by weight in homogeneous materials:

Lead 0,1%
Mercury 0,1%
Cadmium 0,01%
Hexavalent chromium 0,1%
Polybrominated biphenyls (PBB) 0,1%
Polybrominated diphenyl ethers (PBDE) 0,1%
Bis(2-Ethylhexyl) phthalate (DEHP) 0,1%
Benzyl butyl phthalate (BBP) 0,1%
Dibutyl phthalate (DBP) 0,1%
Diisobutyl phthalate (DIBP) 0,1%

Netgear has taken all reasonable steps to verify the supply line information regarding the absence of the restricted substances.

Exceptions for lead (Pb) subject to 2011/65/EU Annex III:
6(a), 6(a)-I Lead as an alloying element in steel containing up to 0.35% lead by weight, and as a copper alloy 6(c.) (ie. Brass) containing up to 4% lead by weight. Netgear products are compliant."

The exceptions part needs an update for mid 2021.

can't be difficut 8-)

[rohs_issue]

Hello,

I really don't know how to proceed.

I already referred to sales@netgear.com according to one of the recommnedations of the posts here, but not response at all.

I will appriciate who can assist.

Thank you,

Ido

[rohs_issue]

Hi,

No response from the mail I sent to sales@netgear.com with reminders.

Where can we find it?

Who can help?

Can I receive a mail address of any responsible handler in Netgear for Help?

Thanks, Ido

[YeZ]

RoHS is on all European Declarations of Conformity found at

www.netgear.com/about/regulatory

Attached is the file of the DoC.

[rohs_issue]

Dear YeZ,

Thank you, but the declaration you attachred, is not related to the requested product.

The document you sent is related to another product (AC1600).

Please provide same document format which refers to the requested product, JGS516-200EUS. Such document will close the issue.

Waiting for your feedback. We need it urgently.

Thank you,

Ido

[YeZ]

DoC attached for JGS516 switch. 

[rohs_issue]

Dear YeZ,

Indeed the product JGS516 is being mentioned now, we cannot find in the document that you sent now the 2015//863 indication.

In the previous declaration, of other model you sent earlier today, there is such indication (but the product is not relevant for us).

Please provide the ROHS deceration for JGS516, which states 2011/65/EU and 2015/863 with Valid ROHS exemptions.

Thanks

[schumaku]

---

@rohs_issue wrote:

Please provide the ROHS deceration for JGS516, which states 2011/65/EU and 2015/863 with Valid ROHS exemptions.

---

@YeZ That's why I wrote above that -all- the "current" DoC require an update - have even provided a sample text  8-)

[rohs_issue]

Dear YeZ,

Thank you.

1. Please advise when is the estimation, that the updated document of JGS516 can be ready and delivered to me?

2. Can we receive Netgear confirmation, by this platform/forum/coommunity, that JGS516-200EUS is ROHS compliant by 2011/65/EU 2015/863 and includes only valid exemptions, as being known up for today?

We will use it as a temporary statement until having the formal letter.

Please update ASAP.

Thank you,

Ido

[YeZ · Accepted solution]

You need the CoC file instead, attached.

You can email environment@netgear.com for any further RoHS related inquries.

Thank you.

Ye