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SIC: 3577 and 3679
Regarding Directives and/or Regulations for RoHS, WEEE,
REACH, Conflict Minerals, and Counterfeit Components
following summarizes our commitment to key directives and/or regulatory requirements
that have been put in force by assorted government and non-government
organizations in order to identify and control various elements and
compounds of concern at all stages of a product's life cycle -- from
sourcing raw materials to disposing of finished products.
|RoHS and WEEE
Technobox is committed to meeting RoHS
requirements. The company sources RoHS-compliant components from our suppliers.
The transition to RoHS began several years ago, starting with the substitution of lead-free components for
existing products. As used herein, lead-free implies compliance with
|In support of the RoHS and WEEE
|Will produce lead-free versions of
existing products, provided all parts used in existing products are
obtainable with reasonable lead times, pricing, packaging, and minimum
quantity requirements from component suppliers.
Will consider redesigning products to adhere to the Directives if an
existing product cannot be directly converted to lead-free
manufacturing. Customers may need to make changes to their
implementation (software, etc.) in order to use such redesigned
Will assign new orderable part
numbers for lead-free products. (Part numbers for existing products that
contain lead will remain unchanged.)
May charge a premium
for lead-free products as required to offset additional recurring and
non-recurring costs incurred to support the Directives.
Will eventually require a signed waiver with
each order for products containing lead. Customers assume all
responsibility for the use and disposition of products.
design and produce new products for compliance with
the RoHS Directive and likely will not be available in versions that
Will implement inspection techniques to
verify vendor claims that components supplied to Technobox are
lead-free (e.g., vendor's product labeling and certificates).
|Technobox produces both leaded and lead-free assemblies and has established processes that assure goods are
manufactured and handled accordingly, including appropriate processing,
handling, and labeling. Separate rework
stations are maintained for both lead-containing and lead-free products.
DIRECTIVES 2011/65/EU (RoHS2) and
DIRECTIVES 2002/95/EC (RoHS1) and
best of our knowledge, articles produced by Technobox do not contain any
of the REACH Substances of Very High Concern (SVHC), as specified in the
table below, according to the Candidate list published by ECHA (European
Chemical Agency). Furthermore, the articles are not intended to release
any substances under normal and reasonably foreseeable conditions of
use. We are working with component manufacturers and others to provide a
more complete response to REACH inquiries regarding Technobox products.
This qualified response is being submitted to satisfy your immediate
request for a REACH compliance statement.
Upon request we will provide a qualified response to satisfy an immediate request for a REACH compliance statement. Technobox is not required to register with
EU Regulation - REACH consolidated version (EN) - 10 Ocotober 2017
European Chemical Agency (ECHA) - Substance Identification
European Chemical Agency (ECHA) - Substance Candidate List
The US Securities and Exchange Commission (SEC) issued the final rule implementing Section 1502 in August 2012. The Dodd-Frank Wall Street Reform and Consumer Protection Act includes Section 1502
Conflict Minerals. This section modifies the Securities Exchange Act of 1934. Publicly traded companies are now required to include disclosures relating to conflict minerals in annual filings. The initial reporting period started in January 2013.
Technobox recognizes the importance of supporting responsible
supply chain managment. We are aware of the efforts of organizations
like the Conflict Free Sourcing Initiative (CFSI) and Electronic
Industry Citizenship Coalition (EICC). Technobox can provide, upon request, a Conflict Minerals Reporting Template (CMRT).
For purchased components, we rely on statements of the original component manufacturers and bare board manufacturers, as do the distributors and representatives
from whom we buy. We review statements and/or templates provided by vendors.
We make no attempt to verify identified sources or otherwise investigate
entities and/or persons cited. Technobox does not buy raw materials.
Securities and Exchange Commission - Conflict Minerals - 17 CFR Parts
240 and 249b
United States Public Law 111-203 - Dodd-Frank Wall Street Reform and
Consumer Protection Act
United States District Court for DC - Civil Action No. 13-cv-635 (RLW) -
Ruling Upholding Section 1502 Conflict Minerals of Dodd-Frank
Electronic Industry Citizenship Coalition (EICC)
Electronic Components Industry Association (ECIA) - Conflict Minerals
Organisation for Economic Co-operation and Development (OECD) - Due
The Conflict-free Sourcing Initiative (CFSI) - Reasonable Practices to Identify
Sources of Conflict
Counterfeit Electronic Part Detection and Avoidance|
Under the National
Defense Authorization Act of 2012, Section 818, the United States Department of Defense (DOD) released a
regulation dictating requirements for counterfeit electronic part detection and avoidance systems and DOD Federal Acquisition Regulation Supplement (DFARS).
On Aug. 2, 2016 the DOD issued a final rule under DFARS Case 2014-D005 making further changes to the
DFARS to address the detection and prevention of counterfeit parts, and establish rules for sourcing electronic parts
so as to mitigate the risk of introducing counterfeit parts within the supply chain. The rule modified the existing clause at DFARS 246-7007 Contractor Counterfeit
Electronic Part Detection and Avoidance System and added a new clause at 252.246-7008 Sources of Electronic
In keeping with the above, Technobox personnel are instructed
to be aware of the importance of counterfeit electronic part detection and avoidance. Approved suppliers are defined by the president and chief engineer who is also solely responsible for purchasing decisions and order placement, as well as vendor relations. Technobox policy is to procure exclusively through OCMs, authorized distributors/resellers as recommended
in a variety of pertinent directives and standards from DOD, SAE, JEDEC, etc.
regarding counterfeit parts issues and detection/mitigation/reporting.
Technobox, however, is not equipped to perform extensive tests on incoming components. All purchased products received at Technobox are verified for the correct amount and part number. Samples are taken from lot and checked against purchase
order and records on database. Nonconforming items, if any, are identified and brought to the attention of management
and segregated. Any incident of counterfeiting will be reported to the Government-Industry Data Exchange Program (GIDEP). Receiving inspections are recorded in the database. Sample is photographed for record. Statements of origin, RoHS, traceability to OCM are provided in paperwork from
Defense Federal Acquisition Regulation Supplement: Detection and Avoidance of Counterfeit Electronic Parts-Further Implementation (DFARS Case 2014-D005)
Defense Federal Acquisition Regulation Supplement: 252.246-7007 Contractor Counterfeit Electronic Part Detection and Avoidance System
Defense Federal Acquisition Regulation Supplement: 252.246-7008 Sources of Electronic Parts.
SAE AS5553B Counterfeit Electrical, Electronic, and Electromechanical (EEE) Parts; Avoidance, Detection, Mitigation, and Disposition
SAE AS6174 Counterfeit Materiel; Assuring Acquisition of Authentic and Conforming Materiel
JESD243 Counterfeit Electronic Parts: Non-Proliferation for Manufacturers
EARI Parts Reporting and Sharing
Government - Industry Data Exchange Program (GIDEP)
Thursday, January 18, 2018 03:10:25 PM
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