Can you show Due Diligence in RoHS compliance if audited?
Yes. The IEC Standards Committees involved in the ISO 9001 Quality Standards are looking at introducing process steps to include the RoHS- and WEEE-Directive. Visit http://www.iecq.org/ (www.IECQ.org) for more details. Many assume that in proving due diligence, you are off the hook with respect to the RoHS-Directive. Not so. Even in the UK where this idea has been circulating, it is clear that the due diligence defense will not carry if it can be proved that your end-item contains more than the legally allowable levels of any of the 6 Hazardous substances. So if you manage a process that can track all pieces, parts and components, that still does not guarantee the parts are compliant.
