Full Material Declarations: Removing Barriers to Environmental Data Reporting

Since the European Directives, RoHS (Restriction of Hazardous Substances) and REACH (Registration, Evaluation, Authorization and Restriction of Chemicals), entered into force in 2006-7, the number of regulated substances continues to grow. REACH adds new substances roughly twice a year, and more substances will be added to RoHS in 2019. While these open-ended regulations represent an ongoing burden for supply chain reporting, some ability to remain ahead of new substance restrictions can be achieved through full material declarations (FMD) specifically the IPC-1752A Class D Standard (the "Standard"), which was developed by the IPC - Association Connecting Electronic Industries. What is important to the supply chain is access to user-friendly, easily accessible or free, fully supported tools that allow suppliers to create and modify XML (Extensible Markup Language) files as specified in the Standard. Some tools will provide enhancements that validate required data entry and provide real-time interactive messages to facilitate the resolution of errors. In addition, validation and auto-population of substance CAS (Chemical Abstract Service) numbers, and Class D weight rollup validation ensure greater success in the acceptance of the declarations in customer systems that automate data gathering and reporting. A good tool should support importing existing IPC-1752A files for editing; this capability reduces the effort to update older declarations and greatly benefits suppliers of a family of products with similar composition. One of the problems with FMDs is the use of "wildcard" non-CAS numbers based on a declarable substance list (DSL). While the substances in different company's lists tend to have some overlap, no two DSL’s are the same. We provide an understanding of the commonality and differences between representative DSLs, and the ability to configure how much of a non-DSL substance percent is allowed. Case studies are discussed to show how supplier compliance data, can be automatically loaded into the customer's enterprise compliance system. Finally, we briefly discuss future enhancements and other developments like Once an Article, Always an Article (O5A) that will continue to require IPC standards and supporting tools to evolve....