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This article was first presented as a paper at the 2018 IPC Apex Expo Technical Conference and published in the 2018 Technical Conference Proceedings. The previous article in this series was “Beyond “Lead-Free: An Update on the IPC-1752A Standard for Materials Declaration.”
Full material declaration 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, but rather, 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 an 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 full material declarations (FMDs) 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 article, 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’s 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 round of four additional substances, per the European Commissions Delegated Directive 2015/863/EU, will be enforced 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’s 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.