Category Archives: News

IEC 62474 DSL updated with PIP (3:1) – April 28, 2021

On April 28, 2021, the IEC 62474 declarable substances list (DSL) was updated to include recent U.S. TSCA restrictions of PIP (3:1) and decaBDE. The restriction of PIP (3:1) is a particular challenge for manufacturers and suppliers given the incredibly short timeframe and that many manufacturers have not been tracking this substance in their supply chain.

Early indication is that PIP (3:1) may be contained in a variety of EEE products and components – wire sheathing and foam gaskets are emerging as examples. However, most manufacturers do not yet know the full extent of the potential applications. These compliance challenges made PIP (3:1) a priority for addition to the IEC 62474 DSL before the next planned update in July.

The updated DSL (version D22.00) includes a new entry for PIP (3:1) (ID=00174) and modifications to the entry for decaBDE (ID=00064) for reporting threshold and regulatory basis.

The latest IEC 62474 DSL may be referenced with the UniqueID authority=IEC62474, identity= IEC62474-DSL, and version=D22.00.

The DSL is available online from the IEC 62474 database at http://std.iec.ch/iec62474 ; the standard itself which specifies the material declaration rules may be purchased in the same manner as any other IEC standard — from the IEC webstore or a reseller.

IEC 62474 Updates to Declarable Substances List (DSL) and Exemption Lists – 2021 January

The IEC 62474 declarable substance list (DSL) and exemption lists were updated on January 19, 2021, coinciding with the update to the EU REACH Candidate List.  IEC 62474, the International Standard for material declaration for the electrical and electronics industry includes the DSL, exemption lists, material classifications, and material declaration data exchange requirements and format.

Update to IEC 62474 DSL on January 19, 2021

The IEC 62474 Declarable Substance List (DSL) is an internationally recognized and consolidated list of substances that are subject to regulations from around the world. Only substances that the Validation Team for IEC 62474 considers as potentially present in electrical and electronic products and systems are included on the DSL. Manufacturers and suppliers use the DSL in their design and supply chain management to specify and control substances of interest.

Note: Substances on the DSL are declarable, but not always hazardous or restricted. For example, entries may be included on the DSL because the substances and materials are valuable for recovery. This includes critical raw materials (CRMs) which are starting to appear in regulations that require reporting to assist in recycling.

The DSL (version D21.00) was updated (see Table 1) to include the two substances added to the REACH Candidate List on January 19 and a new substance group “Halogenated Flame Retardants” that is focused on enclosures of display products such as computer monitors and televisions.

The substance group for halogenated flame retardants was added to address the restriction specified in EU Regulation (EU) 2019/2021 (laying down ecodesign requirements for electronic displays) coming into effect on 1 March 2021. Unfortunately, the restriction in the regulation is poorly specified with no threshold level and no defined list of substances subject to the restriction. The Commission has an amendment underway to provide a threshold level for verification purposes, but there has been no clarification on exactly which substances meet their definition of a flame retardant. The lack of a definitive list could result in differences of opinion between suppliers and downstream manufacturers.

Table 1: Substances and Substance Group Add to the IEC 62474 DSL

IDSubstance group / Substance nameCAS No.Reportable ApplicationReporting ThresholdTypical EEE Applications
00171Halogenated Flame Retardants(group)enclosure and stand of electronic displays, including televisions, monitors and digital signage displays with a screen area greater than 100 square centimetresIntentionally addedFlame retardant in electronic displays
00172Bis(2-(2-methoxyethoxy)ethyl)ether143-24-8Solvent in electrolyte in lithium-ion batteries, solvent in other manufacturing process (example: solder flux).
00173Dioctyltin dilaurate, stannane, dioctyl-, bis(coco acyloxy) derivs., and any other stannane, dioctyl-, bis(fatty acyloxy) derivs. wherein C12 is the predominant carbon number of the fatty acyloxy moiety(group)All0.1 mass% of articleStabilisers and catalysts in the production of e.g. plastics and rubber. Used for the manufacture of the follow article categories: plastic products, fabrics, textiles, apparel, and leather. Professional application of coatings and inks.

In addition to the newly added DSL entries, two of the existing PFOA related entries (ID=00160 and 00161) had their regulatory basis updated to reflect that they are now restricted under the EU POPs regulation (replacing the REACH Annex XVII restrictions).

Updates to Reference Substance List (RSL)

The newly added SVHC substance group for Dioctyltin dilaurate…  (ID=00173) has three accompanying reference substances as shown in Table 2. Note that entry R00716 uses the CAS name “Stannane, dioctylbis[(1-oxododecyl)oxy]-“ instead of the EC name “Dioctyltin dilaurate” shown on the REACH Candidate List.  They are never-the-less the same substance with the same CAS number.

Table 2: New RSL entries for DSL entry 00173

IDDeclarable Substance GroupReference Substance nameCAS No.
R00716Dioctyltin dilaurate, stannane, dioctyl-, bis(coco acyloxy) derivs., and any other stannane, dioctyl-, bis(fatty acyloxy) derivs. wherein C12 is the predominant carbon number of the fatty acyloxy moietyStannane, dioctylbis[(1-oxododecyl)oxy]-3648-18-8
R00717Stannane, dioctyl-, bis(coco acyloxy) derivs.91648-39-4
R00718dioctyltin dilaurate; stannane, dioctyl-, bis(coco acyloxy) derivs.-

For the substance group “Halogenated Flame Retardants”, taking into consideration that there is no substance list in the EU regulation, the references substances were compiled from existing RSL entries that were already identified as halogenated substances with possible flame-retardant properties. Nearly 200 references substances were identified; however, given the lack of clarity on exactly which substances are restricted, the list should be considered indicative and cannot be considered a complete list.

Update to IEC 62474 Exemption Lists

The IEC 62474 database includes exemption lists for EU RoHS Annex III, EU RoHS Annex IV, and China RoHS. The lists are updated with the intention to remain aligned with their respective regulations, but to also include additional information (such as unique identifiers) and strict version control to improve supply chain communication. Adding exemption lists to the IEC 62474 standard has two main purposes:

  1. to provide a globally standardized way of referencing exemptions in material declarations through the supply chain; and
  2. to provide the ability for regulators (who are implementing cloned regulations) to reference an IEC standardized list of exemptions instead of creating and maintaining their own list.

To help clarify and provide guidance on exemptions with conditions or expiry dates that vary by product category, the IEC 62474 exemption lists partition these exemptions into sub-exemptions. Each sub-exemption specifies unique conditions and an expiry date for the product category.

All three exemption lists were updated on January 19, 2021.  The EU RoHS Annex III and Annex IV lists had significant updates to reflect exemptions that expired, transitioned or were newly added by delegated Directives.  The China RoHS exemption list included a minor update to correct the exemption description for exemption 31. All updates may be identified by filtering on a last revised date of 2021-01-19.

Table 3: IEC 62474 Exemption Lists

List AuthorityList IdentityList Version
IEC62474EU-RoHS-AnnexIIIE2.0
IEC62474EU-RoHS-AnnexIVE2.0
IEC62474China-RoHSE1.1

Additional Information

The DSL and exemption lists are available online from the IEC 62474 database at http://std.iec.ch/iec62474 ; the standard itself which specifies the material declaration rules may be purchased in the same manner as any other IEC standard — from the IEC webstore or a reseller.

IEC 62474 Declarable Substance List Updated – January 16, 2020

The IEC 62474 DSL and RSL were updated on January 16, 2020 to version D19.00. The update included edits to a few existing DSL entries and the addition of two new entries corresponding to two of the four substances (relevant to EEE) that ECHA added to the REACH Candidate List substances on same day.

Changes to Existing DSL Entries

  • The previous declarable substance group “Disodium tetraborates” was modified to “Disodium tetraborate, anhydrous” to align with the REACH Candidate List designation by separating out “Tetraboron disodium heptaoxide, hydrate” as a new declarable substance entry (ID=00163)
  • Notes were added to DSL entries 00138, 00144, 00145, and 00148 to indicate that these substances are polycyclic aromatic hydrocarbon (PAH)
  • A note was added to entry 00046 (Polychlorinated Biphenyls (PCBs) and specific substitutes” to clarify that an EU REACH Regulation Annex XVII entry applies to one or more reference substances in this Declarable Substance Group.
  • Updates that had been made by ECHA to CAS numbers were also made to DSL entries: 00144, 00145, 00157, 00159.

New Entries

  • Two of the four SVHCs that were added to the REACH Candidate List by ECHA on January 16, 2020 were added to the DSL: “Perfluorobutane sulfonic acid (PFBS) and its salts” and “Diisohexyl phthalate”. The other two Candidate List entries were screened and are not added. Four reference substances were added to the RSL for PFBS.

Additional Information

The updated DSL version is D19.00. The new and modified entries have a last revised date of 2020-01-16.

If anyone is aware of errors or omissions in the database (e.g. a regulated substance 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 support on IEC 62474 or your substance management program, please contact ECD Compliance.

IEC 62474 Database Update with Exemption Lists – July 2019

The IEC 62474 (Material Declaration) Database was updated on July 21-22, 2019. This was a very extensive and complex update:

  • There were a significant number of additions and changes made to the IEC 62474 declarable substances list (DSL) and references substance list (RSL) during this update. The new DSL/RSL version is D18.00.
    • One of the four SVHCs added to the REACH Candidate List in July 2019 is a possible constituent of electrotechnical products and therefore included in the DSL;
    • Several other substance groups and substances were added due to emerging regulatory changes;
    • A major review of substance names and synonyms was performed. Changes reflecting this review were included in this update;
    • DSL and RSL entries that are new or changed have a last revised date of 2019-07-21;
    • Entries that were removed can be identified by comparing the new DSL and RSL with D17.01 (see archive section).
  • An update to the complementary list was also posted (CL18.00). This is a list of REACH Candidate List SVHCs that were screened out and not added to the EEE industry DSL.
  • The initial release of exemption lists for EU RoHS Annex III and China RoHS were published as of July 22, 2019. The EU RoHS Annex IV exemption is in final review and will be published soon.
  • There were no changes made to the Material Class List (MCL) — update coming soon
  • The data exchange format (DX) had a major revision (X8.00) based on the revised IEC 62474:2018 standard published last year.
    • The revised XML schema and developer’s table were posted on April 14, 2019.
    • The revision supports a new  Declaration for Compliance module that enables suppliers to provide a summary declaration against a DSL.  It is similar to the IPC-1752A Class C declaration.

Additional information on the Database update is provided below.  For technical support, consulting, or training on this database update or on the full set of new features and changes that were recently added to IEC 62474 or the revised IEC 62474-2018 data exchange format and XML schema, please contact ECD Compliance.

Declarable Substances List (D18.00)

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, reportable applications, and other information that is important for creating a material declaration.

Three new Declarable Substance Groups (DSG) were added to the DSL based on regulatory developments.  This includes TNPP, one of the four SVHC added to the REACH Candidate List on July 16, 2019.  TNPP was the only SVHC that the IEC 62474 Validation Team (VT62474) found may be a constituent of an EEE product above the reporting threshold.  The other three SVHCs were added to the Complementary List (CL18.00) of SVHCs that have been screened out by the team.  Anyone that is aware of new information that a screened out SVHC may exist in EEE above threshold, should contact the VT or ECD Compliance.

The new DSG entries added to the DSL are listed in the table title “New DSL entries”.

New DSL Entries (D18.00)

IDSubstance GroupSpecific SubstanceCAS numberReportable ApplicationsReporting Threshold
00160Perfluorooctanoic acid and its saltsSee Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsAll0.0000025 mass% of PFOA including its salts in article or mixture
00161PFOA-related substancesSee Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsAll0.0001 mass% of one or a combination of PFOA-related substances, in article or mixture
00162Tris(4-nonylphenyl, branched and linear) phosphite (TNPP) with ≥ 0.1% w/w of 4-nonylphenol, branched and linear (4-NP)See Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsAll0.1 mass% of article

Several other updates to declarable substance entries were also made, mostly to adjust declarable substance and declarable substance group names to align with the names used in regulations. There was also an extensive update to the formatting of CAS numbers and Basis Descriptions (i.e. the regulations that are the basis for adding the substance to the DSL).  The use of a standardized format will make it easier for IT systems to automatically parse and extract the relevant information.

The recently added substance clarification data field in the DSL now includes the substance description specified in the REACH Candidate List.  This is a normative field in the DSL and needs to be used to determine whether or not a given substance or mixture falls under the DSL entry.  Substance clarification may also include other information and notes to assist users with the DSL entry. The substance clarifications were simplified in D18.00 compared to version D17.01 – this will make it easier to identify which DSL entries have a substance clarification.

Other changes to DSL entries in this update include:

  • DIBP was added to “Phthalates, Selected Group 1 (DEHP, DBP, BBP, DIBP)” (ID=00036)
  • Several substance and substance group names (including several PAH substances) were adjusted to match the current names in legislation

The revised entries are shown in the table titled “Modified DSL Entries (D18.00)

Modified DSL Entries (D18.00)

IDSubstance GroupSpecific SubstanceCAS numberReportable ApplicationsReporting Threshold
00016Dimethylfumarate (DMF)624-49-7All0.00001 mass% of the part
00036Phthalates, Selected Group 1 (DEHP, DBP, BBP, DIBP)See Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsChildren's toy or child care article0.1 mass% as the sum of the phthalate concentrations in plasticized material
00044Polybrominated biphenyls (PBB)See Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsAll0.1 mass% in homogenous material
00045Polybrominated diphenyl ethers (PBDE)See Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsAll0.1 mass% in homogenous material
00048Polychlorinated naphthalenesSee Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsAllIntentionally added
00056Tris(2-chloroethyl) phosphate115-96-8All0.1 mass% of article
000801,2-Benzenedicarboxylic acid, dipentyl ester, branched and linear84777-06-0All0.1 mass% of article
00081Diisopentyl phthalate605-50-5All0.1 mass% of article
00105Imidazolidine-2-thione (2-imidazoline-2-thiol)96-45-7All0.1 mass% of article
00108Benzo[a]pyrene (BaP)50-32-8Rubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
00109Benzo[e]pyrene (BeP)192-97-2Rubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
00110Benzo[a]anthracene (BaA)56-55-3Rubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
00111Chrysen (CHR)218-01-9Rubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
00112Benzo[b]fluoranthene (BbFA)205-99-2Rubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
00113Benzo[j]fluoranthene (BjFA)205-82-3Rubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
00114Benzo[k]fluoranthene (BkFA)207-08-9Rubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
00115Dibenzo[a,h]anthracene (DBAhA)53-70-3Rubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
00116Benzo[a]pyrene (BaP)50-32-8Rubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
00117Benzo[e]pyrene (BeP)192-97-2Rubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
00118Benzo[a]anthracene (BaA)56-55-3Rubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
00119Chrysen (CHR)218-01-9Rubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
00120Benzo[b]fluoranthene (BbFA)205-99-2Rubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
00121Benzo[j]fluoranthene (BjFA)205-82-3Rubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
00122Benzo[k]fluoranthene (BkFA)207-08-9Rubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
00123Dibenzo[a,h]anthracene (DBAhA)53-70-3Rubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
00138Benzo[def]chrysene (Benzo[a]pyrene)50-32-8All0.1 mass% of article

Reference Substances List (D18.00)

Reference Substances were added for each of the new substance group entries and to a few existing substance groups — see table titled “New Reference Substances in RSL (D18.00).

New Reference Substances in RSL (D18.00)

IDSubstance GroupSpecific SubstanceCAS number
R00513Phthalates, Selected Group 1 (DEHP, DBP, BBP, DIBP)Diisobutyl phthalate (DIBP)84-69-5
R00496Chlorinated Flame Retardants (CFR)1,4:7,10-Dimethanodibenzo[a,e]cyclooctene, 1,2,3,4,7,8,9,10,13,13,14,14-dodecachloro-1,4,4a,5,6,6a,7,10,10a,11,12,12a-dodecahydro-13560-89-9
R00497Chlorinated Flame Retardants (CFR)1,4:7,10-Dimethanodibenzo[a,e]cyclooctene, 1,2,3,4,7,8,9,10,13,13,14,14-dodecachloro-1,4,4a,5,6, 6a,7,10,10a,11,12,12a-dodecahydro-, (1R,4S,4aS,6aS,7S,10R,10aR,12aR)-rel-135821-74-8
R00498Chlorinated Flame Retardants (CFR)1,4:7,10-Dimethanodibenzo[a,e]cyclooctene, 1,2,3,4,7,8,9,10,13,13,14,14-dodecachloro-1,4,4a,5,6,6a,7,10,10a,11,12,12a-dodecahydro-, (1R,4S,4aS,6aR,7R,10S,10aS,12aR)-rel-135821-03-3
R00499Perfluorooctanoic acid and its saltsPentadecafluorooctanoic acid335-67-1
R00500Perfluorooctanoic acid and its saltsAmmonium pentadecafluorooctanoate3825-26-1
R00501Perfluorooctanoic acid and its saltsSodium pentadecafluorooctanoate335-95-5
R00502Perfluorooctanoic acid and its saltsPotassium pentadecafluorooctanoate2395-00-8
R00503Perfluorooctanoic acid and its saltsSilver pentadecafluorooctanoate335-93-3
R00504PFOA-related substancesPentadecafluorooctanoic acid335-67-1
R00505PFOA-related substancesAmmonium pentadecafluorooctanoate3825-26-1
R00506PFOA-related substancesSodium pentadecafluorooctanoate335-95-5
R00507PFOA-related substancesPotassium pentadecafluorooctanoate2395-00-8
R00508PFOA-related substancesSilver pentadecafluorooctanoate335-93-3
R00509PFOA-related substancesPentadecafluoroctanoyl fluoride335-66-0
R00510PFOA-related substancesMethyl pentadecafluorooctanoate376-27-2
R00511PFOA-related substancesEthyl pentadecafluorooctanoate3108-24-5
R00512PFOA-related substances3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-Heptadecafluordecan-1-ol678-39-7
R00514Tris(4-nonylphenyl, branched and linear) phosphite (TNPP) with ≥ 0.1% w/w of 4-nonylphenol, branched and linear (4-NP)Phenol, 4-nonyl, phosphite3050-88-2
R00515Tris(4-nonylphenyl, branched and linear) phosphite (TNPP) with ≥ 0.1% w/w of 4-nonylphenol, branched and linear (4-NP)Phenol, p-isononyl-, phosphite31631-13-7
R00516Tris(4-nonylphenyl, branched and linear) phosphite (TNPP) with ≥ 0.1% w/w of 4-nonylphenol, branched and linear (4-NP)Phenol, p-sec-nonyl-, phosphite106599-06-8

Most of the changes to existing RSL entries were due to adjustments in the names of Declarable Substance Groups. This included:

  • Azocolourants and Azodyes which form certain aromatic amines
  • Phthalates, Selected Group 1 (DEHP, DBP, BBP, DIBP)
  • Polybrominated biphenyls (PBB)
  • Polybrominated diphenyl ethers (PBDE)
  • Polychlorinated naphthalenes

Additional changes to the RSL:

  • The name of the reference substance “Mercuric chloride” (ID=R00174) was changed to “Mercury, chloro(cyclohexylmethyl)-“
  • The duplicate reference substance Lead phosphate (ID=R00157) was deleted – this substance is also listed as Lead (II) phosphate (ID=R00165) (same CAS number) . Lead phosphate was added as a synonym to entry R00165 for completeness.

Exemption Lists

The initial release of exemption lists for EU RoHS Annex III and China RoHS were posted. The EU RoHS Annex IV exemption list is in final review and will be published soon.

When creating a material declaration, the following identity information is applicable:

  • List Authority=”IEC62474″;
  • List Identity=”EU-RoHS-AnnexIII” or “China-RoHS”
  • List Version=”E1.0″.
  • The Entry IDs of individual exemptions are provided in column D of the list.

Based on user input, some of the IEC 62474 exemptions lists have exemptions that are split into sub-exemptions when there are multiple expiry dates or technical requirements that change over time. Each sub-exemption has a sub-exemption ID (referred to as sub-identity). This has the benefit of enabling suppliers who are creating material declarations for their products to more precisely identify the specifics of the exemption they are declaring, including the product categories for which the exemption is valid.  However, the sub-exemption concept has the disadvantage of making the exemption lists more complex, although suppliers do not need to use the sub-exemptions. If a supplier’s part or material is used in many different product categories, they can select the original exemption (sub-identity=’00’).

For additional information on sub-exemptions, see the IEC 62474 blog article on exemption lists.

Given that this is the first release of the IEC 62474 exemption lists, there may be some adjustments based on feedback. Please check the IEC 62474  database regularly for any updates.

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 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 D18.00. The new and modified entries have a last revised date of 2019-07-21.

If anyone is aware of errors or omissions in the database (e.g. a regulated substance 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 support on IEC 62474 or your substance management program, please contact ECD Compliance.

IEC 62474 Material Declaration Exchange Format Adding Declaration for Compliance

On April 14, 2019, the revised IEC 62474 data exchange (DX) format — including XML schema and the Developer’s Table (DT) – was published on the IEC 62474 database.  It introduces several new capabilities to the International Material Declaration Standard for the Electrotechnical industry.

The material declaration information will now be organized in “sectionals”, similar to the way that IPC-1752A uses sub-sectionals and classes.   Each sectional represents a different type of information that may be included in the IEC 62474 material declaration and is represented as an element under ‘Product’ in Figure 1 below. The sectionals include:

  • 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 Support for EU SCIP Database

EU SCIP Database Requirements

The reporting obligations for manufacturers, importers and distributors to have submitted information about their products and first Articles that contains REACH Candidate List SVHCs starts on January 5, 2021. This new regulatory requirements will be a significant challenge for many industries, including automotive, aerospace, defense, heavy equipment, and electronics given that many of these products contain one or more SVHCs due to a lack of technical alternatives. The specifications include several new data requirements that supply chains do not typically report. The ECHA is developing the SCIP database and has said they expect to have it ready for formal submission by October 2020. For additional information on the SCIP, related articles are available on the ECD Compliance news blog.

Support for Supplier Data Declaration for EU SCIP Database Continue reading →

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.