Author Archives: Walter

Substances that are a Trade Secret

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.

Is my material declaration in conformance with IEC 62474?

The IEC 62474 consists of several parts, including the data exchange format (DXF), the Declarable Substances List (DSL), Material Class List (MCL) and Exemption Lists (EL). A material declaration may utilize any and all of these parts. IEC 62474:2018 AM1 states that a material declaration may be in full conformance with IEC 62474 or it may be in conformance with just specific part(s) of the standard. However, if the declaration conforms to only to part(s) of the standard it can only declare conformance to the part(s) that are used. Acceptable statements for declaring conformance are provided in IEC 62474:2018 AM1.

Full conformance to IEC 62474 would require that the responder (supplier or solution provider) use, at a minimum, the IEC 62474 data exchange format, the DSL, and the MCL. The standard also states that a material declaration may be in conformance only with the “IEC 62474 data exchange format” or only with the “IEC 62474 DSL”. This separation of conforming to parts of the standard was done to support the use of IEC 62474 in other declaration requirements and standards.

For a declaration to conform to the IEC 62474 data exchange format, it meets the declaration requirements specified in the IEC 62474:2018 document (Clause 4), the format requirements specified in the IEC 62474 XML schema and the additional requirements in the Developer’s Table. T

The opportunity to declare conformance to just the IEC 62474 data exchange format, enables the declaration against other lists. For example, the IEC 62474 is adopted as the official European material declaration standard (EN 62474) and as such the data exchange format needs to support declaration against a list of regulated EU critical raw materials as per the EU standard EN 45552. If the material declaration meets the requirements of the IEC 62474 data exchange format, but utilizes an alternate DSL, the material declaration can be claimed to conform to the “IEC 62474 data exchange format”.

Technical Support on IEC 62474

ECD Compliance provides consulting support and training to manufacturers, suppliers and solution providers on the emerging capabilities of IEC 62474 and  the supply chain communication. Contact ECD Compliance for additional information.

Which Substances should be Declared?

Only substances that remain in the product should be declared in the material declaration file. Manufacturing chemicals that react, form other chemicals or otherwise do not remain in the product should not be reported. However, in some cases, a chemical reaction may not be complete and some unreacted quantity of an intermediate chemical may remain in the finished product. These chemicals may be reported; in fact, if the intermediate chemical is listed in the IEC 62474 declarable substances list and a quantity above the reporting threshold could reamin in the final product, then it has to be reported m– otherwise the material declaration will not conform with the IEC 62474 requirements.

A common example is the resin and a hardener used to form epoxy. The final epoxy substance must be declared if it is a declarable substance or as a voluntary declaration if it isn’t. The individual resin and hardener chemicals would not be declared unless a residual amount of the chemical remains in the product and then only the residual amount would be declared.

A user may only state that they are in conformance with IEC 62474 if they have included all reportable substances and substance groups that are present in the product above the reporting threshold.

What Should be Reported when a Substance is Really a Mixture of other Substances

Substances with a CAS-number that contain other substances sometimes cause confusion in a material declaration. The CAS-number system does not exclude the possibility that a substance with a CAS-number consists of a number of other substances with CAS-numbers. Examples are:

  • Steel with CAS number 12597-69-2
  • Brass with CAS number 12597-71-6

Each of these substances have a variable composition and may or may not include a reportable substance such as Lead (Pb). Declaring only “Steel” does not give information if lead is a constituent of the alloy or not. If a mixture (whether a solid (e.g. metal alloy), liquid, or gas) contains a declarable substance or declarable substance group, then this declarable substance or declarable substance must always be explicitly reported if present above the reporting threshold and if the reportable application is met.

Another issue that sometime arises in material declarations is when a supplier lists the elements that make up a compound rather than reporting the chemical compound itself. Many declarable substances are compounds which must be reported as listed in the IEC 62474 list of declarable substances. IEC 62474 does not allow the material declaration to report the separate elements that make up the compound. For example Disodium tetraborate, decahydrate (Borax) (CAS-number 1303-96-4 ) consists of Sodium, Boron and Oxygen, with CAS-numbers 7440-23-5, 7440-42-8.and 7782-44-7. Using these elemental CAS-numbers in the declaration will hide the existence of the declarable substance and violates the reporting requirement of IEC 62474.

Calculating Mass Percent for the Material Declaration

Mass information needs to be provided for each of elements in a material declaration that correponds to a physical object or chemical (ie. product, product part, material, substance group, and substance in the figure below). The product element sits at the top of the declaration hierarchy therefore it must always include the mass (a mass percent would be meaningless). For the other elements, the responder who is creating a material declaration generally may provide either the mass or the mass percent.

Conceptual Material Declaration with Optional Declaration of Product Parts and Materials

Conceptual Material Declaration with Optional Declaration of Product Parts and Materials

Mass percent is calculated relative to the element above it in the material declaration. For example, the mass percent of material X is calculated relative to the mass of Product part 1 and the mass percent of Product part 1 is calculated relative to the mass of Product. An exception to the above rule is that the mass percent of substances and substance groups are both calculated relative to the material (or product part / product if material is not declared). A substance mass percent is never calculated relative to the mass of a substance group. This is because substance groups are often unusual grouping of substances and the mass may represent only a part of the substance molecules. For example, Lead/Lead Compounds only considers the Lead atoms and not the entire mass of lead compounds.

If the reporting threshold of a substance or substance group is based on the material (e.g. the RoHS substance thresholds), then the the MatMassPercent element must be used to capture the mass information.

Declaring Exemptions

This guidance document recommends that material declarations include any regulatory exemptions that are applicable to the use of declarable substances and declarable substance groups. Once declared, the standard requires that information about exemptions, must be carried through the supply chain (subclause 4.3.4(f)). Users should check the reportable application to assess whether an exemption is applicable or not to a given application

The IEC 62474 standard is very flexible in allowing users to specify exemptions from one or a multiple of exemption lists. For example, a material declaration may specify both an EU RoHS exemption and simultaneously an EU ELV exemption for a given use of lead. Exemptions may be specified for a substance, a substance group or at the level of the entire product. In most cases, exemptions will be associated with the substance or substance group. The IEC 62474 XML schema does not currently allow exemptions to be associated with product parts or materials.

Users should use exemptions from a recognized and maintained list that is readily available and commonly accepted throughout the electrotechnical industry and supply chain. This is necessary to allow computer processing of the exemptions in the material declaration XML file. Examples of such maintained lists include the IPC 1752 standard and the JAMP material declaration system. Examples of declaring such exemptions are provided in Clause 4 of this guidance document. Within the material declaration file, each Exemptions entry has data fields for “UniqueID” (provides information about the exemption list used) and “Exemption” which identifies the specific exemption that is applicable. The UniqueID field will include the authority — use the exact text string provided by the authority (e.g. IPC) — and the specific exemption list that is used (e.g. see IEC 62474 exemption lists published on the IEC 62474 database). The “Exemption” field will include the identity of the exemption (e.g. ee IEC 62474 exemption lists published on the IEC 62474 databaseand the text based description of the exemption. All of these fields should be copied verbatim from the maintained exemption list that is used. Detailed XML examples of exemptions are provided in clause 4

April 9, 2014 – IEC 62474 database update released

The international IEC 62474 declarable substances list (DSL) and data exchange format was updated on April 9, 2014. IEC 62474 provides the electrical and electronics industry with a material declaration standard and an internationally recognized list of substances that should be declared by suppliers to downstream manufacturers.

Additions to the Declarable Substance List (DSL)
There were several additions and modifications to the Declarable substance groups and declarable substances and the reference substances. The substances added to the DSL are shown in Table 1.

Table 1: Substances/Substance Groups added to the IEC 62474 DSL

Substance GroupSubstance NameCAS numberTypical Applications
Cadmium/Cadmium CompoundsCadmium sulphide1306-23-6Used in photo-resistors, solar cells and piezoelectric tranducers
Trixylyl phosphate25155-23-1Used as a plasticizer for vinyl resin, cellulose resin, natural and synthetic rubber. Also, used as a flame retardant.
Disodium 3,3'-[[1,1'-biphenyl]-4,4'-diylbis(azo)]bis(4-aminonaphthalene-1-sulphonate) (C.I. Direct Red 28)573-58-0Dye for textiles and paper
Imidazolidine-2-thione; (2-imidazoline-2-thiol)96-45-7used as a catalyst in some acrylic adhesive glues which may be used in adhesive tapes (for example, double sided adhesive tapes which may be used to hold the back-light in place in mobile phones)
Perfluorooctanoic acid (PFOA) and individual salts and esters of PFOAsee reference substancesTextiles, photographic coatings applied to films, paper or printing plates and other coated consumer products.

The reporting threshold for the substance group “Perfluorooctanoic acid (PFOA) and individual salts and esters of PFOA ” varies depending on the application. If your material or product contains any of the substances in this substance group, please see the specific reportable applications and reporting thresholds in the online IEC 62474 database. A list of substances that make up this substance group have been provided in the IEC 62474 database under reference substances.

Note: The substance known as C.I. Direct Black 38, which was added to the SVHC Candidate List in December 2013, was not added to the DSL at this time, but may be added during the next update.

Modifications
Modifications were made to the DSL entries for Strontium chromate (Basis changed from criteria 2 to criteria 1) and Di-n-hexyl Phthalate (DnHP) (it’s inclusion in the REACH SVHC Candidate List required a change to the reporting threshold to include “0.1 mass%”. The typical applications for “Cadmium/Cadmium compounds” was updated.

Deletions
The substance “4-[4,4′-bis(dimethylamino) benzhydrylidene] cyclohexa-2,5-dien-1-ylidene] dimethylammonium chloride (C.I. Basic Violet 3)” was deleted from the DSL. The IEC 62474 International validation team reviewed new evidence suggesting that C.I. Basic Violet 3 is not contained in EEE products above the threshold and approved the deletion from the DSL.
Lead di(acetate) was also removed as a reference substance under lead/lead compounds. When Lead di(acetate) was added to the SVHC Candidate List, it was assessed in more detail and the conclusion was that it does not meet the criteria to include it on the DSL. Consequently, the substance was also deleted as a reference substance to avoid confusion.
The revised substance/material lists are version D6.00

Changes to the XML Schema

  1. The sequence of xml element in the substance and substance group classes have been alphabetized for consistency;
  2. A Unique ID element was added to the Substance Group Class allowing users to identify substance groups in their material declaration based on the ID of the substance group in the DSL;
  3. Add a data element (UniqueID class) to Main class to identify name and version of the software tool used to create the material declaration (if used).

Changes to the Developer’s Table

  1. Items 2 and 3 under XML Schema also required changes to the Developer’s Table;
  2. Country information in the material declaration is constrained to use the ISO-3166 standard 2-character country name;
  3. The maximum number of characters allowed for Substance Group and Substance names was increased from 128 to 2048. Some substance names are over 200 characters in length, exceeding the previous 128 character limit;
  4. Mismatch between developer table and xml schema for Unique ID identity attribute
  5. Multiplicity of the Exemption element within the Exemptions class was changed to unbounded to match the XML schema;
  6. Date attributes that did not specify a date format were updated to “Date..8” for consistency
  7. Multiplicity of the Attachment element (ACB079 ) in the BusinessInfo class was changed to unbounded to match the XML schema;
  8. The string length of the “Query statement” attribute was increased from 128 characters to 2048 characters;
  9. The identity code for Substance element in the Material class was changed to ACB121; it was previously a duplicate.

A few other editorial changes were made to the developer’s table to improve clarity.

The updated XML Schema and developer’s table are version X4.00.  Changes in the developer’s table compared to X3.00 are shown in red font.

Further Information

The declarable substance list (DSL) is available for free download at http://std.iec.ch/iec62474. Entries that are new or revised may be identified by a LastRevised date of 2014-04-09 for the DSL and 2014-04-05 for the developer’s table.

Information on previous updates to the IEC 62474 database is available here.

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

The Power of IEC 62474 for Product Compliance and Eco-design

An article about the application and flexibility of material declarations (IEC 62474 in particular) was published in the April 2014 issue of In Compliance magazine. The article titled “The Power of IEC 62474 for Product Compliance and Eco-design” discusses the industry need to identify regulated substances in EEE products and the value of material declarations to assess and document product compliance. EN 50581 – the RoHS 2 harmonized standard for technical documentation – specifically references IEC 62474 because the material declaration standard was written to provide manufacturers with sufficient information to calculate product conformity to substance regulations.

The article addresses such topics as:

  • The Market Need for Material Declarations
  • How material content of products may be used for environmentally conscious design (ECD) (aka eco-design)
  • The role of material declaration data for RoHS 2 compliance
  • A systemic and flexible approach for REACH SVHCs
  • Challenges with material declaration
  • How IEC 62474 helps organizations obtain material declaration data
  • An industry standard declarable substance list
  • Key functionality, flexibility and power of IEC 62474
  • How IEC 62474 material declarations allow conformity to be calculated
  • Keeping the Declarable Substance List up to date

The article is available at the In Compliance website.

IEC 62474 Database update planned for weekend of April 5-6, 2014

An update to the IEC 62474 is planned for the weekend of April 5-6, 2014. The database will be out of service for starting on the Saturday April 5th — a header message will notify users that the DB is out of service. Once the updates have been verified by the IEC 62474 validation team, the header will be updated to indicate that the database is available. Any updates to this schedule will be posted on this blog as well as in the news section of the database.

A technical summary of changes to the declarable substances, reference substances, XML schema and developer’s table will be posted on this blog when the update is complete.