RoHS 3 Statement (2021)

Credentials: 803-COMP-ROHS3 Rev B
Issued On: September 14, 2021

Certification Information

RoHS 3 Statement (2021)

Review the dated source and defined scope for RoHS 3 Statement (2021). Request current, project-specific documentation before relying on it for a purchasing decision. Use this U.S. Nameplate document within its stated date, scope, and conditions. If your supplier-qualification or purchasing process requires current documentation, tell our team which record you need and how it will be used.

RoHS 3 is commonly used to describe the European Union’s restriction framework after four phthalates were added to the substance list in Directive 2011/65/EU. For U.S. Nameplate, the available company document is a supplier statement dated September 14, 2021. That date matters. The letter records what the company and its suppliers understood at that time; it is not a standing legal opinion about every current order or every piece of finished electrical and electronic equipment.

A useful review therefore starts with two separate questions: what does the 2021 statement actually say, and what evidence does today’s project require? Keeping those questions apart prevents a dated declaration from being stretched beyond its wording. It also gives purchasing, engineering, and compliance teams a practical way to ask for information about one defined item.

Start with the document that actually exists

The U.S. Nameplate letter is identified as 803-COMP-ROHS3, Revision B. It states that, to the best of the company’s and its suppliers’ knowledge, U.S. Nameplate products complied with the RoHS requirements described in Directive 2011/65/EU as amended by Directive (EU) 2015/863. The letter then names the ten substances addressed by that amended list.

Its qualifications are just as important as its affirmative sentence. The document says that U.S. Nameplate and its suppliers did not routinely analyze products, that the company could not say its products were 100 percent free of the named substances, and that trace contaminants might be present but were expected to remain below the directive’s maximum thresholds. Those statements make the document a knowledge-based supplier declaration, not a laboratory report.

When a project refers to this letter, identify it by date and revision. Do not shorten it to “U.S. Nameplate is RoHS certified” or use it as a timeless claim. The broader quality standards discussion can help place supplier statements beside other controlled records without changing what this one document proves.

Understand the regulatory frame without turning it into a product verdict

The European Commission describes RoHS as a restriction on certain hazardous substances in electrical and electronic equipment. Directive (EU) 2015/863 replaced Annex II of Directive 2011/65/EU and added four phthalates to the prior six-substance list. The resulting ten are:

  • lead, mercury, cadmium, and hexavalent chromium;
  • polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE); and
  • DEHP, BBP, DBP, and DIBP.

Annex II expresses maximum concentration values by weight in homogeneous materials: 0.1 percent for nine of the substances and 0.01 percent for cadmium. “Homogeneous material” is a more precise basis than averaging a concentration across an entire assembled product. The legal framework also contains scope provisions, application dates, and exemptions. Those details can change how the law applies to a finished item, but this page does not decide that question for a customer.

The manufacturer or other responsible economic operator for the finished equipment should determine applicable law, scope, exemptions, and documentation. A label, overlay, plate, or other supplied component does not independently establish conformity for the equipment that receives it.

Treat a supplier statement as one input, not the whole conclusion

A project team may use a supplier declaration to support a material-compliance file, but the value of that declaration depends on fit. The exact supplied construction, its revision, the date covered, and the evidence expected by the customer all need to align. A statement for an undefined family cannot answer whether a later material change or a different configuration is covered.

This distinction also explains why adjacent records are not interchangeable. A REACH statement addresses a different EU chemical framework. A California Proposition 65 statement concerns a separate California warning law. The ISO 9001:2015 certification page concerns a quality management system. Possessing one of these records does not answer the others.

Connect the question to one purchased construction

A direct way to make a RoHS inquiry concrete is to name the item being bought. Is the request about metal nameplates, rating plates, custom safety labels, graphic overlays, or control panel overlays? Those links help identify the product conversation, but they do not grant a compliance status.

Next, identify the construction rather than relying on the product title alone. A project may need to distinguish substrate, printed or processed layers, adhesive or attachment, protective layer, and any other supplied element that is part of the finished item. U.S. Nameplate should confirm which details are appropriate for the requested item; this page does not infer a standard material stack from a product family.

The customer should also state how that supplied item enters the finished equipment and what date or production revision the review must address. That context allows a response to be tied to a record rather than treated as a general marketing claim.

Build a current request that can be answered precisely

A clear inquiry does not need to be long, but it should remove the ambiguities that make compliance statements easy to overread. A practical sequence is:

  1. Identify the purchased item. Provide the U.S. Nameplate part number, drawing number, quoted construction, or another stable reference.
  2. Define the relevant revision and date. State whether the question concerns a prior shipment, a current quote, or a proposed new construction.
  3. Describe the finished-equipment context. Name the intended market and explain which party has determined that RoHS applies.
  4. State the exact evidence request. Ask whether the project needs a dated supplier declaration, supporting supplier information, analytical data, or another record. Availability must be confirmed rather than assumed.
  5. Call out any exemption or substance-specific issue. The customer or its qualified adviser should identify the applicable provision instead of asking the label supplier to make a legal determination from an incomplete description.
  6. Keep the response with the approved item record. Link the answer to the part and revision reviewed so it is not reused for a different construction without confirmation.

This sequence makes the limitations visible. If a material, supplier, or construction changes, the earlier answer may need to be reviewed again. It also avoids implying that a statement’s file name or page title is itself proof for every future shipment.

Do not infer substance status from the manufacturing route

Process pages can help describe how an item is planned, but a process name does not establish the chemical composition of the completed construction. Screen printing, digital printing, and laminating each identify a manufacturing conversation. None should be used as shorthand for RoHS status.

For the same reason, visual appearance, color, thickness, or an earlier similar order cannot replace item-specific evidence. The review should follow the actual components and records behind the construction under consideration. If supporting information is unavailable, the answer should say so instead of converting an assumption into a declaration.

Read the September 2021 statement with its date intact

The archived Rev B letter remains useful because it shows the scope and limitations of U.S. Nameplate’s statement at a specific time. It names the amended ten-substance framework and expressly discloses the knowledge basis and absence of routine analysis. Its value depends on preserving all of those elements together.

It should not be presented as evidence that current law is unchanged, that every current supplier or construction is identical, or that no restricted substance can be detected. Current legal requirements should be checked through official EU sources, and current item status should be confirmed for the exact order.

Bring one bounded question to the review

Before contacting U.S. Nameplate, gather the item reference, construction or drawing revision, intended market, required response date, and the exact document your organization expects. If the request concerns only one layer or component, identify it. If the customer is relying on an exemption, include the provision selected by its compliance authority.

Use the consultation request to describe that bounded question. U.S. Nameplate can then review the available information for the specified item without turning a dated supplier statement into a blanket promise or deciding the legal obligations of the finished equipment.

Request Current Documentation from U.S. Nameplate

Tell our team which certificate, statement, or supplier document your organization needs, the date or revision required, and the project or qualification process it supports. We will respond using the current information available for that request. Request a Quote.

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