Revised IEC 62474:2018 Flexibility for Material Declarations

The IEC 62474:2018 standard introduces several new and revised capabilities to the International Material Declaration Standard. The new capabilities based on emerging regulatory requirements, user feedback, and the needs of a broad range of industries. It provides significant flexibility for suppliers to provide material declaration information while ensuring that critical information for downstream manufacturers to assess product compliance is always available. The Data Exchange Format now includes a new Declaration for Compliance module and additional support for EU REACH compliance and the upcoming EU Substance of Concern in Products (SCIP) database.  The changes were also intended to make the standard useful to a broad range of industries and different stages in the supply chain given the intertwined nature of global supply chains. .

The material and substance information in the material declaration are organized into declaration modules referred to as “sectionals”.   A hierarchical data representation of the “Product” type in the XML schema was shown in Figure 2. The declaration modules (types of declarations) that may be included in the IEC 62474 material declaration are:

  • Declaration for Compliance;
  • Composition Declaration;
  • Material Class Declaration;
  • Query Statement Declarations (represented by QueryList)

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

The Composition Declaration is used by a responder (supplier) to provide a hierarchical declaration of substances within materials and/or product parts that make up the product.  IEC 62474 requires that at least DSL substances that are present in the product be reported in a composition declaration, but it may include other substances, up to and including a full material declaration (FMD).  Some of the declaration features in the Composition Declaration (most of which are optional) include:

  • The capability for the supplier to provide information about product parts in the build hierarchy and materials (optional). An indefinite hierarchy of product parts is allowed by the Composition Declaration (i.e. product parts may be further partitioned into product parts);
  • Declaration of a DSL that indicates the minimum set of declarable substances that have been declared if they are present in the product;
  • True/False flags enabling the responder to indicate if the Composition Declarations is a full material declaration (FMD) and/or if it includes required information for SCIP submission;
  • Information about the materials in the product including: material class (or material category), material properties and use descriptions
  • The ability to identify substances based on a variety of different conventions, including DSL entry, CAS registry number, EC number, REACH Candidate List entry, etc. If the substance is part of a declarable substance group, it’s also possibly to ‘tag’ the substance with a substance group ID – this assist the downstream manufacturers with compliance assessment;
  • Applicable exemptions to substance restrictions that are needed by downstream manufacturers in assessing compliance

The Declaration for Compliance is a simplified true/false declaration against each entry in a Declarable Substance List (DSL), indicating whether the declarable substance (DS) or declarable substance group (DSG) is present in the product. The Declaration for Compliance typically does not include information on product build hierarchy (see exception below), but it includes sufficient information for the downstream manufacturer to be able to assess compliance against the regulations covered by the DSL.

An exception to including build hierarchy information in the Declaration for Compliance is when the declaration provides information needed for an EU SCIP database submission.  In the SCIP use case, information about the lowest-level (first) Articles containing the REACH Candidate List SVHCs are needed. This use case will be described in future blog posts once the functionality has been finalized and published by the IEC 62474 Validation Team.

If the material declaration is intended to cover multiple DSLs, then multiple instances of ‘Compliance’ may be declared – one for each DSL. The Compliance declaration module also includes a flag to indicate if the sufficient information has been provided for a

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.

Strategic and Technical Support on IEC 62474

For consulting support or training on IEC 62474 or your substance management program, contact ECD Compliance.