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IEC 62474 Material Declaration Exchange Format Adding Declaration for Compliance

The second edition IEC 62474 :2018 published last November introduces several new and revised capabilities to the International Material Declaration Standard for the Electrotechnical industry.

The IEC 62474 data exchange format (XML Schema and Developer’s Table) (Version X8.00) was published on April 14, 2019. The material and substance information in the material declaration will now be organized in “sectionals”, similar to the way that IPC-1752A uses sectionals/classes.   A graphical representation of the “Product” type in the XML schema is shown in the figure below.

The sectionals (types of declarations) that may be included in the IEC 62474 material declaration are shown under the Product element, including:

  • Declaration for Compliance (represented by the Compliance element in figure below);
  • Composition Declaration (represented by the Composition element);
  • Material Class Declaration (represented by MaterialClassDeclaration);
  • Query Statement Declarations (represented by QueryList)

Note: the three additional elements shown under product (ProductID, Attachment, and Exemptions) provide additional information, but are not considered to be sectionals.

A material declaration that conforms to IEC 62474:2018 needs to include at least a Declaration for Compliance or a Composition Declaration but it may also include both.

Figure 1: Graphical Representation of Product Complex Type (generated using Liquid Studio)

 

 

 

 

 

 

 

 

 

Declaration for Compliance

The Declaration for Compliance is a true/false declaration against each entry in a Declarable Substance List (DSL), indicating whether or not the declarable substance (DS) (or declarable substance group (DSG)) is present in the product. This is similar to a Class C declaration in IPC-1752A. The Declaration for Compliance does not include any information on product build hierarchy, but it includes sufficient information for the recipient of the material declaration to be able to assess compliance against the regulations covered by the DSL.

For a declaration for compliance, the supplier creating the declaration would select true for a given DS/DSG entry if:

  • The DS or DSG is a constituent of the product being declared;
  • The DS/DSG may be present above the reporting threshold level; and
  • the reportable application is applicable.

Composition Declaration

The Composition Declaration may be used by the supplier to provide information about product parts, materials and/or substances that make up the product.  IEC 62474 requires that at least declarable substances that are present in the product be reported, but the Composition Declaration may include other substances, up to and including a full material declaration (FMD).

The Composition Declaration also supports declaration and identification of articles (as per the EU REACH regulation) to help manufacturers meet EU REACH SVHC reporting requirements (see related post “Reporting REACH SVHCs using the is Article Flag in IEC 62474 Declarations”)

We will be adding additional information on the revised IEC 62474 material declaration exchange format once the new schema and Developer’s Table are published in the IEC 62474 database.

 

IEC 62474 –Exemption Lists to be Posted on IEC 62474 Database

The IEC 62474 ED2 (published November 2018) includes a provision to post and maintain substance exemption lists on the IEC 62474 database.   Three lists have been approved so far (see Table 5) and will be posted in March 2019 when the upgraded IEC 62474 database features come on line.

Table 5: Exemptions Lists Approved for Publication on IEC 62474 Database

Regulatory BasisList authorityList identityInitial List version
EU RoHS 2 Annex III
(2011/65/EU)
IEC62474EU-RoHS-AnnexIIIE1.0
EU RoHS 2 Annex IV
(2011/65/EU)
IEC62474EU-RoHS-AnnexIVE1.0
China RoHS 2IEC62474China-RoHSE1.0

The initial release of the EU RoHS Annex III exemptions will include all of the exemption renewals that were published in 2018 and the additional ten Delegated Directives published in February 2019.

Identification of Exemption Lists

Each exemption list will be identified by the List authority = “IEC62474”, a list identity, and a list version.  The list identity will remain fixed for a given regulation and the list version will be revised every time that an edit is made to the list. The list version is in the format Emmm.n where ‘mmm’ represents the major revision number and ‘n’ represents a minor editorial update.

Identification of Exemption Entries

Each exemption entry will also have a unique ID consisting of three parts: a base ID, a version ID, and a sub-exemption identity (explained below).  This IEC-ID is intended to uniquely and permanently identify a specific exemption even when a regulation re-uses an exemption number after significantly modifying the technical aspects or scope of an exemption.

The IEC-ID for each entry is of the format “nnnnn-vv-ss”, where nnnnn = base ID number, vv = version (alphabetic), and ss = sub-exemption ID (sub-identity).

Sub-exemptions: Exemption Details that Vary over Time or by Product Category

A unique aspect of the IEC 62474 exemption lists is that exemptions with technical requirements that change over time or have different effective/expiry dates based on product category will be subdivided into sub-exemptions that each have a unique technical requirement, effective date and/or expiry date. Each sub-exemption will share the base ID and version ID of its parent exemption but will have a unique sub-exemption identity (referred to as the sub-identity).

For example, the revised exemption 6(a) that comes into effect on July 1, 2019 is excerpted in Table 6. The example lists three sub-exemptions with different expiry dates for most category 8/9 products, category 8 in vitro, and category 9 industrial.  The IEC-IDs for the three sub-exemptions are: 00033-B-01, 00033-B-02, 00033-B-03 – the last two digits indicate the sub-identity. The original exemption as specified in the regulation always has the sub-identity ‘00’.

Table 6: Selected columns for the revised exemption Annex III 6(a)

IEC-IDregIndexDescriptionScope and dates of applicabilityEffective DateExpiry Date
00033-B-006(a)Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0.35 % lead by weightExpires on:
− 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
− 21 July 2023 for category 8 in vitro diagnostic medical devices;
− 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
July 1, 2019Multiple
00033-B-016(a)Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0.35 % lead by weightExpires on:
− 21 July 2021 for categories 8 and 9 other than in vitro diagnostic medical devices and industrial monitoring and control instruments;
July 1, 2019July 21, 2021
00033-B-026(a)Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0.35 % lead by weightExpires on:
− 21 July 2023 for category 8 in vitro diagnostic medical devices;
July 1, 2019July 21, 2023
00033-B-036(a)Lead as an alloying element in steel for machining purposes and in galvanised steel containing up to 0.35 % lead by weightExpires on:
− 21 July 2024 for category 9 industrial monitoring and control instruments, and for category 11.
July 1, 2019July 21, 2024

Other Information Included in the Exemption List File

The IEC 62474 exemption lists also provide additional information about each exemption such as the regulatory basis for the exemption and the DSL entry that the exemption applies to. “First Added” and “Last Revised” dates are provided to record when a specific entry was added or changed in the exemption list.

Format of the Exemption Lists (xls vs XML)

The IEC 62474 exemption lists are initially provided only as spreadsheets in xls format but may be migrated to an XML format in the future.  The XML format will make it easier for IT systems to automatically import revisions to the exemption list.

Additional Support

For additional support on the exemption lists or in implementing other features associated with the 2nd edition IEC 62474:2018, contact ECD Compliance.

IEC 62474 – Amendment 1 to Broaden Use Across Industries

IEC 62474 Ed 2 is undergoing a quick amendment to broaden its use across multiple industries by allowing alternate Declarable Substance Lists (DSL) to be used in creating a material declaration.

A few other clarifications are also being made. The voting period for the IEC 62474 AM1 Committee Draft for Vote (CDV) closes on April 19th. If all National Committees (NC) approve the document, the amendment can skip the final draft (FDIS) voting and go straight to publication.

There are no other technical changes in Am1 that impact the data exchange format or the information on the IEC 62474 database.

IEC 62474:2018 is available from the IEC webstore and standards resellers worldwide.  The revision has also been approved as a European Standard (EN 62474).

IEC 62474 – Ed.2 Data Exchange Format to be Released in March 2019

The IEC 62474 data exchange format, including XML schema and developer’s table (DT) are being updated based on the requirements specified in the updated ED2 standard. Several new features have also been requested, including:

  • Flag to indicate that the declaration is a full material declaration
  • Safe use information, identifying a safe use condition from a list or a separate statement
  • A tag to identify declarable substance groups associated with a substance in a composition declaration
  • Identification of standardized or industry specified query lists
  • Attachments at Material and Product Part levels

The revised format has been approved, including all of the proposed new features. A final review and adjustments are being made. The revised data exchange format will be published around mid-March.

IEC 62474 Declarable Substance List (DSL) – July 2018 Update

The IEC 62474 Declarable Substance List (DSL) was updated to Version D16.00 on July 8, 2018. The update includes relevant SVHCs from the recent update to the EU REACH Candidate List and a few other changes to declarable substance and reference substance entries as described below.

Declarable Substance List (DSL)
Eight of the ten SVHCs added to the REACH Candidate List on June 27th were included in the DSL based on their potential presence in EEE products. The substance review for possible EEE uses was conducted by the IEC 62474 Validation Team (VT62474) with experts from Asia, Americas, and Europe. Note: if anyone is aware of information that may be relevant to whether or not one of the substances may be present in EEE products, please forward the information to the VT (by sending an email to iec62474(at)rohs.ca).

One of the additions, the phthalate DCHP, had been proposed for the Candidate List in 2016, but the Member State Committee (MSC) representing the EU countries couldn’t agree as to whether or not it met the requirements for listing. The substance was referred to the European Commission who made the final decision and issued Commission Implementing Decision (EU) 2018/636 in April to add the substance.

The additions to the DSL are listed in Table below.

One entry was deleted from the DSL. The restriction of BNST (Benzenamine, N-phenyl-, reaction products with styrene and 2,4,4-trimethylpentene) was repealed by Canada and the DSL entry (ID=00127) was accordingly deleted from the DSL.

IDSpecific SubstanceCAS numberCommon SynonymsTypical ApplicationsReportable ApplicationsReporting Threshold
00148Benzo[ghi]perylene191-24-2Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersAll0.1 mass% of article
00149Octamethylcyclotetrasiloxane556-67-2D4Siloxanes are monomers used to manufacture silicones. They may remain as unreacted in silicone polymers and copolymers, used in many electrotechnical equipment product categories.All0.1 mass% of article
00150Decamethylcyclopentasiloxane541-02-6D5Siloxanes are monomers used to manufacture silicones. Residuals may remain in silicone polymers and copolymers.All0.1 mass% of article
00151Dodecamethylcyclohexasiloxane540-97-6D6Siloxanes are monomers used to manufacture silicones. They may remain as unreacted in silicone polymers and copolymers, used in many electrotechnical equipment product categories.All0.1 mass% of article
00152Disodium octaborate12008-41-2Wooden veneer sheets and pressed wooden panels (as a constituent within the starch adhesive), as a flame retardant, as stabilizer in aminoplastic resins, and as a biocide in professional and industrial wood preservation.All0.1 mass% of article
00153Terphenyl, hydrogenated61788-32-7 Plasticizers, sealants, epoxy adhesives, paints and heat sinksAll0.1 mass% of article
00154Lead7439-92-1Steel, aluminum and copper alloys, lead acid batteries, solder and other applicationsAll0.1 mass% of article
00139Dicyclohexyl phthalate84-61-7DCHPPlasticizer, dye, pigment, paint, ink, manufacture of adhesive, lubricantAll0.1 mass% of article

Reference Substance List (RSL)
Nine reference substances were deleted from the Reference Substance List (RSL). The substances are SVHCs that are on the REACH Candidate List; however, they have been previously screened out because no applications were found whereby the substances would remain in EEE products at or above the reporting threshold level. To avoid confusion that can arise when a regulated substance is on the RSL but not on the DSL, the VT 62474 agreed to remove the substances from the RSL for consistency.

One other RSL entry was modified. The RSL entry R00147 (substance name “Hexabromocyclododecane (HBCDD)”) was modified to remove the CAS registry number “3194-55-6”. In January 2018, a new entry (R00492) was added to the RSL with the specific substance represented by this CAS number  (1,2,5,6,9,10-hexabromocyclodecane), so listing the CAS number against the generic substance entry was no longer needed. To avoid confusion from having the same CAS number listed in two different RSL entries for the same substance group, the CAS number was removed from the generic entry.

Additions and modifications to the Reference Substance List (RSL) are shown in the Table below.

Type of ChangeIDSubstance GroupSpecific SubstanceCAS number
DeletedR00099Cadmium/Cadmium compoundsCadmium chloride10108-64-2
DeletedR00100Cadmium/Cadmium compoundsCadmium sulfate10124-36-4, 31119-53-6
DeletedR00103Chromium (VI) CompoundsChromium trioxide1333-82-0
DeletedR00104Chromium (VI) CompoundsSodium chromate7775-11-3
DeletedR00105Chromium (VI) CompoundsSodium dichromate10588-01-9, 7789-12-0
DeletedR00107Chromium (VI) CompoundsPotassium dichromate7778-50-9
DeletedR00108Chromium (VI) CompoundsPotassium chromate7789-00-6
DeletedR00162Lead/Lead CompoundsLead (II) oxide1317-36-8
DeletedR00204Ozone Depleting Substances (CFC, Halon, HBFC, HCFC & others)1-Bromopropane106-94-5
ModificationR00147Hexabromocyclododecane (HBCDD)Hexabromocyclododecane (HBCDD)25637-99-4

Material Class List (MCL)
No changes were made to the MCL during this update to the IEC 62474 database. However, a major revision to the Material Class List is currently underway — the changes will better support Life Cycle Assessment (LCA) of EEE products.

Upcoming Major Changes to the IEC 62474 Standard and Database
The IEC 62474 standard was due for its periodic review and revision a couple years ago (like any other IEC standard) and the IEC/TC111 Maintenance Team has been working hard to improve the standard based on feedback we’ve received from many users and other stakeholders.

The FDIS version (Final Draft International Standard) of the revised standard was completed in March and is currently in translation; it should be available for voting at the end of July (voting is by country). In the interim, the VT62474 is busy drafting the changes to the XML schema to meet the new requirements and compiling other information that will be added to the database such as new data fields for the DSL and exemption lists. We will be posting additional information on this site over the next few months.

For immediate guidance, ECD Compliance supports manufacturers, solution providers, and suppliers on the implementation of IEC 62474. We can work with you on the transition to the new requirements and provide implementation guidance. For additional information, contact ECD Compliance.

The IEC 62474 Database
The IEC 62474 DSL is available on the IEC 62474 database at: http://std.iec.ch/iec62474. The new and modified entries have a last revised date of 2018-07-08.

IEC 62474 Declarable Substance List – Sept 2017 Update

The IEC 62474 Declarable Substance List (DSL) was updated on September 3, 2017. The updated version (D14.00) includes the additional SVHC added to the REACH Candidate List in July (Perfluorohexane-1-sulphonic acid and its salts) and changes to two existing DSL entries and some maintenance to reference substance list entries, including:

  • The nickel substance entry (nickel metal) is replaced by a nickel/nickel compounds declarable substance group with tenreference substances;
  • The numerical part of the reporting threshold of Hexabromocyclododecane (HBCDD) was reduced to 0.01 mass% of article to align with the EU POPs regulation; and
  • The reference substance name “Lead hydrocarbonate” was replaced by “Trilead bis(carbonate) dihydroxide” and the duplicate reference substance “Lead (II) carbonate basic” (same CAS, different name) was delected.

The DSL is used globally by EEE manufacturers, suppliers, and IT solution providers as a common list of substances that should be declared throughout the supply chain, allowing downstream manufacturers to access product compliance to substance regulations around the world. The DSL includes declarable substances and substance groups together with reporting thresholds and reportable applications.

Additions and modifications to the DSL  are listed in the table below

IDSubstance GroupSpecific SubstanceCAS numberReportable ApplicationsReporting Treshold 
00020Hexabromocyclododecane (HBCDD) and all major diastereoisomers identified: Alpha-hexabromocyclododecane Beta-hexabromocyclododecane Gamma-hexabromocyclododecaneSee Reference Substance worksheet for more detailsSee Reference SubstancesAllIntentionally added or 0.01 mass% of article
00031Nickel/Nickel CompoundsSee Reference Substance worksheet for more detailsSee Reference SubstancesAll, where prolonged skin contact is expectedIntentionally Added
00143Perfluorohexane-1-sulphonic acid and its saltsSee Reference Substance worksheet for more detailsSee Reference SubstancesAll0.1 mass% of article

Additions and modifications to the Reference Substance List are listed in the tables below

IDSubstanceGroupSpecificSubstanceCASnumber
R00478Nickel/Nickel CompoundsNickel7440-02-0
R00479Nickel/Nickel CompoundsNickel (II) oxide1313-99-1
R00480Nickel/Nickel CompoundsNickel (II) chloride7718-54-9
R00481Nickel/Nickel CompoundsNickel (II) chloride, hexahydrate 7791-20-0
R00482Nickel/Nickel CompoundsNickel(II) sulfate7786-81-4
R00483Nickel/Nickel CompoundsNickel(II) sulfate, hexahydrate10101-97-0
R00484Nickel/Nickel CompoundsNickel(II) sulfate, heptahydrate10101-98-1
R00485Nickel/Nickel CompoundsAntimony nickel titanium oxide yellow8007-18-9
R00486Nickel/Nickel CompoundsNickel niobium titanium yellow rutile68611-43-8
R00487Nickel/Nickel CompoundsCobalt titanate green spinel68186-85-6
R00488Perfluorohexane-1-sulphonic acid and its saltsPerfluorohexane-1-sulphonic acid355-46-4
R00489Perfluorohexane-1-sulphonic acid and its saltsammonium perfluorohexane-1-sulphonate68259-08-5
R00490Perfluorohexane-1-sulphonic acid and its saltspotassium perfluorohexane-1-sulphonate3871-99-6
R00491Perfluorohexane-1-sulphonic acid and its saltssodium perfluorohexane-1-sulphonate2923-26-4
R00154Lead/Lead CompoundsTrilead bis(carbonate) dihydroxide1319-46-6

Background

The IEC 62474 DSL is an internationally recognized and harmonized list of substances and substance groups that are regulated and may be constituents of electrical and electronic products and systems. Electrical and electronic manufacturers and suppliers use the DSL in their design and supply chain management operations to specify and control substances of concern. The list is typically updated as needed based on regulatory changes. For additional information about IEC 62474, see the article About IEC 62474. The IEC 62474 database is available online; the standard itself which specifies the material declaration requirements and rules may be purchased in the same manner as any other IEC standard — from the IEC webstore or a reseller.

 Additional Information

The updated DSL version is D14.00. The new and modified entries have a last revised date of 2017-09-03

If anyone is aware of errors or omissions in the database (e.g. a regulated substances that is not included in the DSL but has potential EEE applications) or a regulatory reference that is out of date, please send an email to ECD Compliance and we will raise the issue with the  IEC 62474 validation team.

For further information on IEC 62474 or for support on your substance management program, please contact ECD Compliance.

 

 

 

 

IEC 62474 Declarable Substance List – Jan 2017 Update

The IEC 62474 Declarable Substance List (DSL) was updated on January 12, 2017 following the European Chemical Agency (ECHA) addition of substances to the EU REACH Candidate List on the same day. The update includes those of newly added REACH SVHCs that may be constituents of EEE products. A few additional maintenance updates were also made.

The DSL is used globally by EEE manufacturers, suppliers, and IT solution providers as a common list of substances that should be declared throughout the supply chain, allowing downstream manufacturers to access product compliance to substance regulations around the world. The DSL includes declarable substances and substance groups together with reporting thresholds and reportable applications.

The update includes:

  • two of the four SVHCs added to the EU REACH Candidate List on January 12, 2017
  • reference substances for one of the SVHCs that is a group of substances
  • an update to the reportable application field of one of the Lead/Lead compound substance groups
  • deletion of two reference substances

The IEC 62474 data exchange format (XML schema and developer’s table) was not updated during this maintenance cycle. There were no changes made to the Material Classes.

Declarable Substance List (DSL)

Additions and modifications to the DSL  are listed in the table below

IDSubstance GroupSpecific SubstanceCAS numberReportable ApplicationsReporting Threshold
001414,4’-isopropylidenediphenol (BPA, Bisphenol A)80-05-7AllIntentionally added or 0.1 mass% of article
00142Nonadecafluorodecanoic acid (PFDA) and its sodium and ammonium salts See Reference SubstancesSee Reference SubstancesAll0.1 mass% of article
00021Lead/Lead CompoundsSee Reference SubstancesSee Reference SubstancesAll, except for: 1. batteries, 2. surface coating material of cables/cords with thermoset or thermoplastic coatings, and 3. paint and similar surface coatings of toys and other articles intended for use by children
0.1 mass% of total Pb in homogenous material

Bisphenol A (BPA) was added to the REACH Candidate List and, given that the substance has several applications in EEE manufacturing, was included in the IEC 62474  DSL.

For the Lead/Lead Compounds entry with ID=00021 a clarification was made to the reportable application field.  There are a total of five different Lead/Lead Compound entries with different reporting thresholds for different reportable applications. The clarification helps ensure that the correct threshold is being applied for each application.

Reference Substance List

Additions and deletions to the Reference Substance List are listed in the tables below

Reference Substance List - Additions

IDSubstanceGroupSpecificSubstanceCASnumber
R00474Nonadecafluorodecanoic acid (PFDA) and its sodium and ammonium salts Nonadecafluorodecanoic acid335-76-2
R00475Nonadecafluorodecanoic acid (PFDA) and its sodium and ammonium salts Decanoic acid, nonadecafluoro-, sodium salt3830-45-3
R00476Nonadecafluorodecanoic acid (PFDA) and its sodium and ammonium salts Ammonium nonadecafluorodecanoate3108-42-7
R00477Chlorinated Flame Retardants (CFR)Tris(1,3-dichloro-2-propyl)phosphate13674-87-8

Reference Substance List - Deletions

IDSubstanceGroupSpecificSubstanceCASnumber
R00164Lead/Lead CompoundsLead hydroxidcarbonate1344-36-1
R00289Perfluorooctane sulfonates (PFOS)Perfluorooctanoic acid sodium salt335-95-5

Background

The IEC 62474 DSL is an internationally recognized and harmonized list of substances and substance groups that are regulated and may be constituents of electrical and electronic products and systems. Electrical and electronic manufacturers and suppliers use the DSL in their design and supply chain management operations to specify and control substances of concern. The list is typically updated as needed based on regulatory changes. For additional information about IEC 62474, see the article About IEC 62474. The IEC 62474 database is available online; the standard itself which specifies the material declaration requirements and rules may be purchased in the same manner as any other IEC standard — from the IEC webstore or a reseller.

 Additional Information

The updated DSL version is D13.00. The new and modified entries have a last revised date of 2017-01-12.

If anyone is aware of errors or omissions in the database (e.g. a regulated substances that is not included in the DSL but has potential EEE applications) or a regulatory reference that is out of date, please send an email to ECD Compliance and we will raise the issue with the  IEC 62474 validation team.

For further information on IEC 62474 or for support on your substance management program, please contact ECD Compliance.

IEC 62474 DSL Updated to Align with “Article” Interpretation

The IEC 62474 Declarable Substance List (DSL) was updated (D11.00) on March 28, 2016 to reflect the September 2015 European Court of Justice (ECJ) interpretation of the term “article”. The ECJ ruling is important for OEMS and suppliers in determining whether a REACH Candidate List SVHC is above the 0.1 mass% threshold that triggers communication and notification obligations under the EU REACH regulation. A summary of the ECJ ruling is available from the blog post EU Judgment – SVHC Reporting Required for First Article.

The 71 REACH SVHCs entries in the DSL have had their reporting threshold revised to “0.1 mass% of article” to indicate that the threshold refers to an individual article.

In developing a solution to align the DSL with the ECJ ruling, the IEC 62474 validation team (VT) considered the possibility of using the term “product part” to represent an article; however, a “product part” in a material declaration can be used to represent any of several levels of subassemblies and components in a EEE product. Therefore, in many situations, it may not always be a match for the REACH definition of article.

The VT also discussed the possibility of including some type of guidance to assist manufacturer in using the threshold in the context of electrical and electronic products. However, given that guidance on the practical interpretation of “article” is still the subject of intense discussion by regulators, politicians industry and other stakeholders for the next release of the European Chemical Agency (ECHA) guidance document on substances in articles, it wouldn’t be appropriate for the VT to try to second guess the conclusion of this work.  Once ECHA publishes its guidance document with examples, the IEC 62474 DSL may be revised again to support the guidance.

Reporting Levels

With the ECJ ruling addressed, the new “ReportingLevel” field, which was recently added to the database, was populated.  The ReportingLevel field is intended to simplify for users the interpretation of the more complex reporting thresholds. Some of the reporting thresholds are difficult to interpret because of how they are written in the regulation. For example, some thresholds refer to a part, but the actual intention from the regulation is material.

The ReportingLevel for a  given DSL entry indicates one of four possible values: Product, Product Part, Article or Material.

Changes to Declarable Substance Groups

There were a couple of additional minor DSL changes.

The scope of the substance group “Polychlorinated Naphthalenes (PCNs)” was expanded to include all such substances with 1 or more chlorine atoms Previously only substances with  more than 3 chlorine atoms were consider to be included in the group. The change is based on the additional requirements of the EU POP regulation.

For consistency in substance naming, the substance group  “4-Nonylphenol, branched and linear, ethoxylated [substances with a linear and/or branched alkyl chain with a carbon number of 9 covalently bound in position 4 to phenol, ethoxylated covering UVCB- and well-defined substances, polymers and homologues, which include any of the individual isomers and/or combinations thereof]” was abbreviated to “4-Nonylphenol, branched and linear, ethoxylated” to align with the IEC 62474 substance naming convention. The portion of the  name that appears in square brackets is not actually part of the chemical name but rather a description of the substance group.  This description has been moved to the comment field in the DSL entry.

Reference Substances

Given the expanded scope of the Polychlorinated Naphthalenes (PCNs) substance group, a large number of additional references have been added in place of the generic reference substance “Other polychlorinated Naphthalenes”. The added reference substances are listed in Table 1 below.

Four additional reference substances have been list for the substance group “4-Nonylphenol, branched and linear, ethoxylated”. The new entries are shown in Table 2.

 Material Classes and the XML Schema

 No changes were made to the material classes or the XML Schema during this update.

Table 1: Reference Substances Added for Polychlorinated Naphthalenes (PCNs)

Substance GroupSpecific SubstanceCAS number
Polychlorinated Naphthalenes (PCNs)1-Chloronaphthalene90-13-1
Polychlorinated Naphthalenes (PCNs)2-Chloronaphthalene91-58-7
Polychlorinated Naphthalenes (PCNs)1,5-Dichloronaphthalene1825-30-5
Polychlorinated Naphthalenes (PCNs)1,4-Dichloronaphthalene1825-31-6
Polychlorinated Naphthalenes (PCNs)1,2-Dichloronaphthalene2050-69-3
Polychlorinated Naphthalenes (PCNs)1,6-Dichloronaphthalene2050-72-8
Polychlorinated Naphthalenes (PCNs)1,7-Dichloronaphthalene2050-73-9
Polychlorinated Naphthalenes (PCNs)1,8-Dichloronaphthalene2050-74-0
Polychlorinated Naphthalenes (PCNs)2,3-Dichloronaphthalene2050-75-1
Polychlorinated Naphthalenes (PCNs)2,6-Dichloronaphthalene2065-70-5
Polychlorinated Naphthalenes (PCNs)1,3-Dichloronaphthalene2198-75-6
Polychlorinated Naphthalenes (PCNs)2,7-Dichloronaphthalene2198-77-8
Polychlorinated Naphthalenes (PCNs)Chloronaphthalene25586-43-0
Polychlorinated Naphthalenes (PCNs)Dichloronaphthalene28699-88-9
Polychlorinated Naphthalenes (PCNs)Pentachloronaphthalene1321-64-8
Polychlorinated Naphthalenes (PCNs)Trichloronaphthalene1321-65-9
Polychlorinated Naphthalenes (PCNs)Hexachloronaphthalene1335-87-1
Polychlorinated Naphthalenes (PCNs)Tetrachloronaphthalene1335-88-2
Polychlorinated Naphthalenes (PCNs)Perchloronaphthalene 2234-13-1
Polychlorinated Naphthalenes (PCNs)1,4,6-Trichloronaphthalene2437-54-9
Polychlorinated Naphthalenes (PCNs)1,4,5-Trichloronaphthalene2437-55-0
Polychlorinated Naphthalenes (PCNs)1,4,5,8-Tetrachloronaphthalene3432-57-3
Polychlorinated Naphthalenes (PCNs)1,2,4,8-Tetrachloronaphthalene6529-87-9
Polychlorinated Naphthalenes (PCNs)1,2,4,5-Tetrachloronaphthalene6733-54-6
Polychlorinated Naphthalenes (PCNs)1,2,3,6,7,8-Hexachloronaphthalene17062-87-2
Polychlorinated Naphthalenes (PCNs)1,2,3,4-Tetrachloronaphthalene20020-02-4
Polychlorinated Naphthalenes (PCNs)1,3,5,8-Tetrachloronaphthalene31604-28-1
Polychlorinated Naphthalenes (PCNs)Heptachloronaphthalene32241-08-0
Polychlorinated Naphthalenes (PCNs)2,3,6,7-Tetrachloronaphthalene34588-40-4
Polychlorinated Naphthalenes (PCNs)1,2,4-Trichloronaphthalene50402-51-2
Polychlorinated Naphthalenes (PCNs)1,2,3-Trichloronaphthalene50402-52-3
Polychlorinated Naphthalenes (PCNs)1,3,5-Trichloronaphthalene51570-43-5
Polychlorinated Naphthalenes (PCNs)1,2,6-Trichloronaphthalene51570-44-6
Polychlorinated Naphthalenes (PCNs)1,2,4,6-Tetrachloronaphthalene51570-45-7
Polychlorinated Naphthalenes (PCNs)1,2,3,5-Tetrachloronaphthalene53555-63-8
Polychlorinated Naphthalenes (PCNs)1,3,5,7-Tetrachloronaphthalene53555-64-9
Polychlorinated Naphthalenes (PCNs)1,2,3,5,7-Pentachloronaphthalene53555-65-0
Polychlorinated Naphthalenes (PCNs)1,2,5-Trichloronaphthalene55720-33-7
Polychlorinated Naphthalenes (PCNs)1,2,7-Trichloronaphthalene55720-34-8
Polychlorinated Naphthalenes (PCNs)1,2,8-Trichloronaphthalene55720-35-9
Polychlorinated Naphthalenes (PCNs)1,3,6-Trichloronaphthalene55720-36-0
Polychlorinated Naphthalenes (PCNs)1,3,7-Trichloronaphthalene55720-37-1
Polychlorinated Naphthalenes (PCNs)1,3,8-Trichloronaphthalene55720-38-2
Polychlorinated Naphthalenes (PCNs)1,6,7-Trichloronaphthalene55720-39-3
Polychlorinated Naphthalenes (PCNs)2,3,6-Trichloronaphthalene55720-40-6
Polychlorinated Naphthalenes (PCNs)1,2,3,7-Tetrachloronaphthalene55720-41-7
Polychlorinated Naphthalenes (PCNs)1,3,6,7-Tetrachloronaphthalene55720-42-8
Polychlorinated Naphthalenes (PCNs)1,4,6,7-Tetrachloronaphthalene55720-43-9
Polychlorinated Naphthalenes (PCNs)1,2,3,4,5,6,7-Heptachloronaphthalene58863-14-2
Polychlorinated Naphthalenes (PCNs)1,2,3,4,5,6,8-Heptachloronaphthalene58863-15-3
Polychlorinated Naphthalenes (PCNs)1,2,3,4,5,6-Hexachloronaphthalene58877-88-6
Polychlorinated Naphthalenes (PCNs)1,2,4,7-Tetrachloronaphthalene67922-21-8
Polychlorinated Naphthalenes (PCNs)1,2,5,6-Tetrachloronaphthalene67922-22-9
Polychlorinated Naphthalenes (PCNs)1,2,5,7-Tetrachloronaphthalene67922-23-0
Polychlorinated Naphthalenes (PCNs)1,2,6,8-Tetrachloronaphthalene67922-24-1
Polychlorinated Naphthalenes (PCNs)1,2,3,4,5-Pentachloronaphthalene67922-25-2
Polychlorinated Naphthalenes (PCNs)1,2,3,4,6-Pentachloronaphthalene67922-26-3
Polychlorinated Naphthalenes (PCNs)1,2,3,4,5,7-Hexachloronaphthalene67922-27-4
Polychlorinated Naphthalenes (PCNs)1,2,4,5,6,8-Hexachloronaphthalene90948-28-0
Polychlorinated Naphthalenes (PCNs)1,2,4,5,7,8-Hexachloronaphthalene103426-92-2
Polychlorinated Naphthalenes (PCNs)1,2,3,4,5,8-Hexachloronaphthalene103426-93-3
Polychlorinated Naphthalenes (PCNs)1,2,3,5,7,8-Hexachloronaphthalene103426-94-4
Polychlorinated Naphthalenes (PCNs)1,2,3,5,6,8-Hexachloronaphthalene103426-95-5
Polychlorinated Naphthalenes (PCNs)1,2,3,4,6,7-Hexachloronaphthalene103426-96-6
Polychlorinated Naphthalenes (PCNs)1,2,3,5,6,7-Hexachloronaphthalene103426-97-7
Polychlorinated Naphthalenes (PCNs)1,2,3,6-Tetrachloronaphthalene149864-78-8
Polychlorinated Naphthalenes (PCNs)1,2,6,7-Tetrachloronaphthalene149864-79-9
Polychlorinated Naphthalenes (PCNs)1,2,5,8-Tetrachloronaphthalene149864-80-2
Polychlorinated Naphthalenes (PCNs)1,2,3,8-Tetrachloronaphthalene149864-81-3
Polychlorinated Naphthalenes (PCNs)1,2,7,8-Tetrachloronaphthalene149864-82-4
Polychlorinated Naphthalenes (PCNs)1,2,3,7,8-Pentachloronaphthalene150205-21-3
Polychlorinated Naphthalenes (PCNs)1,3,6,8-Tetrachloronaphthalene150224-15-0
Polychlorinated Naphthalenes (PCNs)1,2,3,6,7-Pentachloronaphthalene150224-16-1
Polychlorinated Naphthalenes (PCNs)1,2,4,6,7-Pentachloronaphthalene150224-17-2
Polychlorinated Naphthalenes (PCNs)1,2,3,5,6-Pentachloronaphthalene150224-18-3
Polychlorinated Naphthalenes (PCNs)1,2,4,5,7-Pentachloronaphthalene150224-19-4
Polychlorinated Naphthalenes (PCNs)1,2,4,5,6-Pentachloronaphthalene150224-20-7
Polychlorinated Naphthalenes (PCNs)1,2,4,7,8-Pentachloronaphthalene150224-21-8
Polychlorinated Naphthalenes (PCNs)1,2,4,6,8-Pentachloronaphthalene150224-22-9
Polychlorinated Naphthalenes (PCNs)1,2,3,6,8-Pentachloronaphthalene150224-23-0
Polychlorinated Naphthalenes (PCNs)1,2,3,5,8-Pentachloronaphthalene150224-24-1
Polychlorinated Naphthalenes (PCNs)1,2,4,5,8-Pentachloronaphthalene150224-25-2

Table 2: Newly added reference substances for 4-Nonylphenol, branched and linear, ethoxylated

Substance GroupSpecific SubstanceCAS number
4-Nonylphenol, branched and linear, ethoxylatedEthanol, 2-(4-nonylphenoxy)-104-35-8
4-Nonylphenol, branched and linear, ethoxylatedIsononylphenol ethoxylate37205-87-1
4-Nonylphenol, branched and linear, ethoxylatedPoly(oxy-1,2-ethanediyl), alpha-(4-nonylphenyl)-omega-hydroxy-, branched127087-87-0
4-Nonylphenol, branched and linear, ethoxylated4-tert-Nonylphenol diethoxylate156609-10-8

IEC 62474 DSL Update – Version D10.00

Version D10.00 of the IEC 62474 Declarable Substance List (DSL) and the Reference Substance List (RSL) were released on December 17, 2015. The substance lists are used globally by EEE manufacturers, suppliers, and IT solution providers as a common list of substances and substance groups that are declared throughout the supply chain. Declaration of the substances are important for downstream manufacturers to determine conformity of EEE products to substance regulations around the world and to perform due diligence in conformity assessment.

The update includes:

  • four of five substances from the December 17, 2015 SVHC additions to the EU REACH Candidate List and
  • changes in the reporting threshold of the four phthalate substances that were added to the EU RoHS Directive earlier this year.

The IEC 62474 data exchange format (XML schema and developer’s table) was not updated during this maintenance cycle.  The database update is the final step in maintenance cycle (MC-2015-02) which was started in September.

Background

The IEC 62474 DSL is an internationally recognized and harmonized list of substances and substance groups that are regulated and may be constituents of electrical and electronic products and systems. Electrical and electronic manufacturers and suppliers use the DSL in their design and supply chain management operations to specify and control substances of concern. The list is typically updated as needed based on regulatory changes. For additional information about IEC 62474, see the article About IEC 62474. The IEC 62474 database is available online (free of charge); the standard itself which specifies the material declaration requirements and rules may be purchased in the same manner as any other IEC standard — from the IEC webstore or a reseller.

Additions to the Declarable Substance List (DSL)

Additions and technical modifications to the DSL were driven by two regulations: EU REACH and EU RoHS. The new entries are listed in the table below

New and Modified Substance Entries in the DSL - D10.00

SubstanceCAS numberTypical ApplicationsReporting ThresholdRegulation
Bis (2-ethylhexyl)phthalate (DEHP)117-81-7Plasticizer, dye, pigment, paint, ink, adhesive, lubricant0.1 mass% in homogenous materialEU RoHS
Dibutyl phthalate (DBP)84-74-2Plasticizer, dye, pigment, paint, ink, adhesive, lubricant0.1 mass% in homogenous materialEU RoHS
Benzyl butyl phthalate (BBP)85-68-7Plasticizer, dye, pigment, paint, ink, adhesive, lubricant0.1 mass% in homogenous materialEU RoHS
Diisobutyl phthalate84-69-5Plasticizer, dye, pigment, paint, ink, adhesive, lubricant0.1 mass% in homogenous materialEU RoHS
1,3-propanesultone1120-71-4Electrolyte fluid of rechargeable lithium ion batteries 0.1 mass%REACH Candidate List
2,4-di-tert-butyl-6-(5-chlorobenzotriazol-2-yl)phenol (UV-327)3864-99-1UV stabilizer0.1 mass%REACH Candidate List
2-(2H-benzotriazol-2-yl)-4-(tert-butyl)-6-(sec-butyl)phenol (UV-350)36437-37-3UV stabilizer0.1 mass%REACH Candidate List
Perfluorononan-1-oic-acid and its sodium and ammonium salts375-95-1, 21049-39-8, 4149-60-4Surfactant in the production of the fluoropolymer polyvinylidene fluoride (PVDF)0.1 mass%REACH Candidate List

EU REACH Candidate List

Four of the five SVHCs added to the REACH Candidate List on December 17, 2015 were identified as being possible constituents of EEE products and are therefore included in the DSL. The validation team did not find any evidence that the other SVHC added to the Candidate List would exist in EEE above the reporting threshold.

Note: The reporting threshold for the new REACH SVHC substance entries is listed as “0.1 mass%” in the same manner as the other REACH SVHCs listed in the DSL; however, the IEC 62474 validation team is working on a systemic change to the reporting thresholds to take into account the European Court of Justice ruling in September with regard to the interpretation of article.

EU RoHS

The four Phthalates DEHP, DBP, BBP, and DIBP were added into the EU RoHS Directive with the restrictions taking effect starting on July 22, 2019. Although the restriction date is several years out, some of these phthalates are pervasively used in EEE and will take significant time and effort to eliminate. Adding these substances to the IEC 62474 DSL now is necessary to help manufacturers identify the use of these substances throughout their supply chain.

The original six RoHS substance entries were also updated to reflect the recast Directive 2011/65/EU instead of the original 2002/95/EC.   This is a minor editorial change.

New data field for Reporting Level

A number of new features were added recently to the IEC 62474 database. This includes a new data field has been added to all DSL entries for “Reporting Level”. This field is currently blank, but will used in the near future to provide additional information to help users interpret the reporting threshold. You can find additional information on the new features added by the IEC IT team in an earlier posting.

Changes to the Reference Substance List (RSL)

Two minor changes were made to the Reference Substance List (RSL).

  • The CAS number 31119-53-6 was added to the entry for Cadmium sulfate
  • The CAS number 7789-12-0 was added to the entry for Sodium dichromate

 Material Classes

There were no changes to the Material Classes.

 Additional Information

If anyone is aware of errors or omissions in the database (e.g. a regulated substances that is not included in the DSL but has potential EEE applications) or a regulatory reference that is out of date, please send an email to ECD Compliance and we will review and address with the  IEC 62474 validation team.

For further information on IEC 62474 or for support on your substance management program, please contact ECD Compliance.

IEC 62474 Database Gets Some New Features

On December 14, 2015, the IEC Central Office rolled out some new features in the IEC 62474 database.  The features improve the usability of the database and also provide some new features to support the validation team that maintains the database.

The most significant changes relevant to users include:

  • A new data field for “Reporting Level” has been added to each Declarable Substance List (DSL) entry (more detail on this is provided below)
  • The Export button for the reference substance (RSL) list has been moved further left to make it more visible when a user has a narrow browser window.
  • Users may now export the RSL as an XML file
  • The header message at the top of the browser window that indicates that database status and version now includes a scroll bar to allow users to review the entire message when using a narrow browser window
  • The substance drop-down has been narrowed by showing only the first 30 characters and last 20 characters of a substance or substance group name. The drop-down used to be over 200 characters wide due to some very long substance names. Narrowing the drop-down list makes substance selection more practical. When a specific substance is selected, the entire substance name appears in light grey just below the drop-down box.

The New “Reporting Level” field

Some of the reporting thresholds are quite complex and it’s not always easy to determine whether the reporting threshold applies to a material, a product part, or the entire product. The intention of the “Reporting Level” field is to clearly indicate the basis for the reporting threshold (i.e. what should be used as the denominator when calculating the mass percent for comparing to the reporting threshold). The “reporting Level data fields are currently left blank but will be filled in once the IEC 62474 validation team decides how to address the impact of the recent European Court of Justice ruling on REACH interpretation of article.

Contact ECD Compliance for information on how we can assist your business with setting up a material declaration system and conformity assessment procedures.