Full Material Declarations: Removing Barriers to Environmental Data Reporting

Estimated reading time: 6 minutes

Full material declaration (FMD) of product content in electronics and other industries continues to be a challenge for both suppliers and customers alike. For suppliers, managing substance-level data for all the materials in products is not usually a part of normal business operations; rather, it is an added burden and therefore cost to doing business. Customers, from mid-supply chain enterprises to OEMs, must have processes and systems to request, manage, and utilize the data to ensure compliance with worldwide substance regulations. These issues call out for easy-to-use software solution to aid reporting.

The IPC-1752A Materials Declaration Management Standard, which is aligned with IPC-1751A Generic Requirements for Declaration Process Management, is widely used for environmental reporting today. The standard specifies an XML (extensible markup language) schema for mandatory and required data, including support for Class D FMDs (full material declarations) for homogenous materials and substances required by the RoHS directive (the full citation for the current "RoHS Recast" legislation is "Directive 2011/65/EU 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").

In this paper, we focus on requirements for tools that enable rapid and accurate reporting of Class D FMDs that can be used by suppliers primarily in the base of the supply chain (e.g., raw materials and smaller components). We also provide examples of how this data can be used by the supplier’s immediate customer to build more complex FMD data for product-level assemblies.

Why Take the Road to FMD?

One of the advantages of the FMD approach is that it is the only way a company can stay ahead of the ongoing addition of regulated substances. RoHS has been relatively static in this regard—with only changes being to allowable exemptions and additional documentation requirements. Otherwise, the basic six restricted substances have stayed the same from its initial entry into force through its “Recast” in 2011. The next addition of four additional substances, per the European Commissions Delegated Directive 2015/863/EU, will enter into force July 22, 2019. However, customers across the supply chain are already asking for data and compliance conclusions for these substances. This pre-enactment customer driven activity clearly demonstrates just how valuable FMDs can be since suppliers with FMD data can already satisfy their customer’s requests about the presence of newly (and yet-to-be) restricted substances.

Since RoHS exemptions have set expiration dates, it is also prudent to know what exempted substance is present, besides just knowing you are compliant with exemption but not exactly why. Since exemptions are substance-specific, this level of information is very useful as a warning that a noncompliance could develop when a product that was once acceptable to ship is no longer compliant because the exemption has expired! FMD data provides the ability to look ahead in time for exemptions that are set to expire, allowing the company to take early action through product redesign or finding alternate suppliers. REACH (Registration, Evaluation, Authorization and Restriction of Chemicals), promulgated by a separate agency, ECHA (European Chemicals Agency), is much more dynamic and adds new substances of very high concern (SVHC) to the candidate list roughly twice a year ever since 2008. Figure 1 shows the number of substances added to REACH since its beginning in October 2008 through the last date as of this writing. Shorter gray bars count the substances added each date, with the larger black bars indicating the cumulative total of substances.

Figure 1: Number of REACH SVHCs from 2008 to present. (Black bars = total; Gray bars = added each date.)

Note there is some double counting in the Figure 1 data, since a few of the substances were listed a second time due to different toxicological reasons. Also, note that the count is based on just the primary list of SVHC posted by ECHA in its main table, but the actual individual substance count by CAS number is even greater if one consults the ECHA supporting documentation. Further, it is noted that Amendment 3 of IPC-1752A, which is not fully published as of the time of this writing, will contain a non-exhaustive list of substances and their CAS numbers as a convenient reference to this ever-growing list of substances.

Useful information about the standard and its implementation and advantages may be found on the IPC web page, Data Exchange Standards. Additional advantages of FMD have been published, for example, by companies offering such services, companies needing FMDs from their suppliers, industry conferences, and articles in electronics journals. The story continues and the message remains clear: Companies need a way to stay ahead of the growing list of new substances they are required to manage. FMDs are the best way to do so.

Requirements Part One: The Schema is the Roadbed

In the next sections, we list and explain the value of functional requirements that a good, basic FMD reporting tool should have. At the most basic level, the tool by its nature will be software, and to be used for reporting up the supply chain the XML declaration file must conform to the IPC standard itself. In recent years, the chairs and participants in the IPC 2-18b Materials Declaration Task Group have graciously offered their time and expertise to help review, on a blind submission basis, XML files including Class D FMDs. Using software tools that are available for checking conformance to the schema as specified in the standard, as well as a review by IPC 2-18b participants, those software solution providers that have been verified in this review process and found to conform to the schema in their test files are listed by IPC.

Table 1: IPC Validated FMD Tool Providers.

As the relatively recent history of the IPC review process shows in Table 1, a handful of solution providers have supported and continue to support Class D FMDs, as well as the other reporting classes A and C (not shown). It may be concluded that there are enough competent software solution providers to offer a choice, yet not be overwhelming for companies just embarking on the journey to generate FMDs. Specific company names can be found on the IPC web site as cited above.

Some of the basic requirements for conformance to the standard schema include the following:

• All mandatory data elements (tags) are present, which must be completed when entering data into the tool, if not already present from some prior data entry or load. These elements include data like supplier and customer IDs and part numbers, and homogenous materials in the product broken down by substances and their weights.
• Ability to enter the most useful optional data elements as desired, or as requested by the customer. For example, substance weight is mandatory, but concentration is optional.
• Ability to incorporate a legal statement, either with a standard boilerplate or by entering a custom statement.
• Tags identifying the data as Class D (FMD) based on substance reporting at the homogeneous material level; class C substance category reporting at the product level; or Class A query/reply format (true/false compliance statements).
• Further details including a complete list of mandatory and optional data may be found in the IPC-1752A standard.

To read the full version of this article, which appeared in the July 2018 issue of SMT007 Magazine, click here.