Subject: File No.
From: David Gillies

February 2, 2017

I represent a small contract manufacturer of Cable assemblies and wire harnesses. Almost all the cable, wire, and connectors we purchase for inclusion in our products contain either Tin or Gold.

We have no issue with the intent of the CM rule. The actual implementation is excessive and onerous. Obtaining all the potential smelter data, given the number of tiers that the product passes through, has proven to be very difficult.

Since 2005, we have had to deal with the EU RoHS legislation restricting the use of 6 heavy metals. Once implemented, this legislation evolved to the party actually applying the metals to certify that they were free (compliant) of these 6 heavy metals.

Can the CM process be modified so that the organization that is buying the metals from the refiners and applying them to the product, carry out the due diligence/audits and then simply certify that the product is CM compliant? The upstream users then simply have to ensure that the product has been certified and then they can certify that their higher level product is compliant.

Bringing the process into line with the RoHS process would satisfy the intent of the legislation, and greatly simplify the process, making it more realistic in expectations.