Managing RoHS and REACH compliance declarations continues to be burdensome for most companies. Although both regulations have been around for many years now, the process for collecting and managing declarations is still complex.
Dr. Aidan Turnbull is the Director of BOMcheck.net and the co-chair of the IPC 1752A standards committee. He is a pioneer in data collection standards and methodologies with a focus in electrical and electronic components. He works closely with major companies such as Philips, Dassault, PTC, and SGS.
What are some of the benefits of leveraging the IPC data collection standards?
More and more companies are being asked to supply RoHS and REACH compliant parts.
This requires companies to continually ask their supply chains for updated declarations to cover each new added substance. This creates duplicate activities up and down the supply chain with data needing to be created in multiple formats each time.
Getting everyone on the same page and unifying how industries collect data is critical to reducing costs and saving time and energy.
IPC saw this challenge many years ago and decided to take it on. The IPC 1752A standard has been around since 2006 when ROHS was first introduced. We’ve continued to monitor regulation requirements, update, and expand the standard as time has moved on.
This standard benefits suppliers and their customers by establishing a data format for reporting materials and substances information throughout the supply chain making it easier to collect data and import and export the data to internal systems.
How is the IPC 1752A better than the way companies collected data in the past?
Prior to the 1752A standard companies had to use formats like Word documents, Excel spreadsheets, and PDFs in a non-standardized way to exchange the data.
The old version of the IPC 1752 standard launched in 2006 and was previously supported by two Adobe PDF forms which suppliers could use to generate their XML declarations. However, these old PDF forms had many inherent problems. We’ve had to work with our peers out in industry to develop a better way to collect the data.
Today, IPC 1752A materials declarations are provided in XML format (eXtensible Markup Language), a widely used data exchange language which is used to communicate business information through the internet.
Can you give me a high-level overview of the standard and how ceormgypparnoi.ecso muse it today?
The IPC 1752A standard defines the content and requirements for four classes of declarations, three of which are used by industry today:
- Class A declarations require the supplier to provide Yes or No responses to query statements at the regulation level. For example, a Yes or No response to the statement
“This product meets EU RoHS requirements without any exemptions”. This declaration class was popular in 2006 when customers needed to identify quickly which parts must be replaced with RoHS-compliant alternatives. Today many customers want more than a Yes/No statement for RoHS, REACH and other regulations - Class C declarations require the supplier to report every substance category in a regulation which is present above the threshold level in the part. For example, if any homogenous materials in the part exceed the RoHS threshold for lead/lead compounds then the supplier shall report the worst case concentration at the homogenous material level and shall also report if any exemptions are applicable.
- Class D declarations enable the supplier to provide Full Materials Declarations by reporting the mass of each homogenous material in the part and the mass of each substance in each material and if any exemptions are applicable.
Today, most companies want to achieve a class D declaration because it is has the most complete information about the part. Depending on the system the company is using to manage their declarations, they may not have to ask the supply chain for more information.
Do companies implement the standard themselves or through third party tools?
The standard relies on third party solution providers to develop tools for suppliers to use to generate their XML declarations.
Companies can implement the standard themselves, especially if they have internal teams that can develop software to import, export, analyze, and report their compliance.
Most companies however, leverage the standard through the use of third party tools. These tools can be standalone data providers with developed toolsets, modules that are part of product lifecycle management (PLM) systems, or through outsourced data collection providers.
How do the solution providers know they are developing tools that align with the standard?
Starting in 2014, IPC introduced an annual review process to determine a list of verified solution providers. Many companies leverage this recognition as a verified IPC 1752A solution provider as part of their marketing strategy. Companies who receive this recognition have to submit sample files that have been verified to the current IPC 1752A requirements.
In February 2014 IPC established an open annual review committee. The committee developed two data sets for solution providers to report against:
- supplier part which does not contain any RoHS or REACH substances, and
- supplier part which is compliant to RoHS based on exemptions and contains a REACH Candidate List Substance above 0.1% by weight of the part
Each solution provider’s XML files were reviewed by at least three review committee members. IPC communicated the results of the review process to each solution provider and specified any required improvements. The review committee inspected the solution providers’ example XML files by checking whether the IPC 1752A lists had been used correctly to report the data in the two data sets.
Is there a list of approved IPC solution providers online?
This list is published at http://www.ipc.org/ContentPage.aspx?pageid=Materials-Declaration.
If you could sum it all up, what would you say are the most important points for using the standard today?
Leveraging the standard in an organization takes away some of the onerous and time consuming work of creating processes and standards for collecting compliance data. It also helps minimize confusion in the supply chain by getting companies on the same page. Suppliers can then focus on one format for reporting.
Keep in mind, the IPC 1752A Standard for Materials Declaration Management is the most widely used format for communicating compliance information through the supply chain for electrical and electronic products. The standard is maintained and regularly updated by industry experts to meet changing legislation and industry requirements. The standard improves data quality and reduces cost by providing a standardized format for reporting material declaration data throughout the supply chain.
IPC will continue to work closely with all industry stakeholders to improve the practical implementation of the IPC 1752A standard. IPC will also continue its annual review process to verify that solution providers’ XML files meet the current IPC 1752A requirements. This annual review process provides business benefits to suppliers and customers and will continue to further increase the quality of materials declarations for RoHS and REACH. Using the IPC 1752A standard is an effective method for exchanging data globally and reduces the overhead noise of exchanging that data.
Bio:
Kelly Eisenhardt is Co-Founder and Managing Director at BlueCircle Advisors, an environmental compliance and sustainability consulting and training firm based in Massachusetts (www.bluecircleadvisors.com.) In her role at BlueCircle Advisors, she is responsible for providing business intelligence, strategy and implementation of environmental, social and governance (ESG) risk programs. Her experience aligns well with her client’s needs for technology, compliance, and sustainability expertise by helping companies create and manage their corporate environmental and social responsibility programs.
To contact Kelly Eisenhardt, send emails to kelly.eisenhardt@bluecircleadvisors.com or follow her on Twitter @KelEisenhardt. For more information about BlueCircle Advisors and the company’s products and services, please visit www.bluecircleadvisors.com, on Facebook at BlueCircle Advisors, on Twitter @OurBlueCircle, and on the LinkedIn group at the BlueCircle Advisors group.