Material declarations are a sensitive topic for material and part manufacturers that are using certain chemicals that they consider a trade secret. The chemical, its application, and/or the exact composition usually provides a competitive advantage that the manfuacturer wishes to protect.

The IEC 62474 material declaration standard allows manufacturers flexibility on how much of the chemical composition of the product they wish to declare. A manufacturer could provide a full material declaration of all substances except for those that are trade secrets.

However, if the “trade secret” includes a substance or substance group that is listed on the IEC 62474 declarable substances list (DSL) with a mandaotry reporting requirement and it is present above the reporting threshold, then there is no flexibility; it must be included in the material declaration. The mandatory reporting requirement indicates that the substance is regulated and if it is used in a confidential manner, it can still cause a product to become non-compliant to a legal obligation. Therefore, it is not allowed to leave out or try to hide such a substance in the material declaration.