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.

Declarable Substance List (DSL)

The IEC 62474 Declarable Substance List (DSL) is a list of regulated substances and substance groups (e.g. lead and lead compounds) that a manufacturer should declare to downstream manufacturers if present in the product. Each substance or substance group entry in the list is accompanied with a reportable application and a reporting threshold level. The supplier that is creating the material declaration will use this information to determine if the substance must be declared.

The DSL may be accessed from the IEC 62474 database via the menu bar on the left side of the introduction webpage – click on “Declarable substance groups and declarable substances” and then select the substance from the drop down list. For example, selecting “Lead/Lead Compounds” presents five entries with different reportable application / reporting threshold combinations – the first entry corresponds to the RoHS restriction. Clicking on the “Details” button reveals information about reference substances; typical EEE applications, regulations, and other information.

There is also an option on the website to export the entire DSL.

User Guidance document for IEC 62474

A user guidance document for the IEC 62474 materials declaration standard is in the works. The guidance, which will be designated IEC 62474-1, is being written by the original working group that developed IEC 62474. The expected publication date is late 2014. It will provide information on:

  • how to create a materials declaration in xml;
  • how to handle many complex (and sometimes confusing) declaration situations
  • examples of typical material declarations

How to declare a substance that belongs to two different substance groups in IEC 62474

A material declaration that conforms to IEC 62474 requires that a declared substance must be assigned to it’s respective substance group (if the substance group is declared in the material declaration). In most material declarations this is straightforward. However, there is a corner case emerging when a substance has two or more possible declarable substance groups that are reportable. For example, the REACH SVHC substance “Lead sulfochromate yellow” creates such a situation. The declarable substance groups “Lead/Lead Compounds” and “Chromium (VI) Compounds” are both relevant. Howevever, it’s not possible to have “Lead sulfochromate yellow” declaration assigned to both substance groups simultaneously in the XML file. This situation potentially creates a small amount of double reporting for users that roll-up the total content of specific substances/elements. The IEC 62474 standard is vague on how to deal with this.

Let’s look at this situation in more detail….

Subclause 4.2.3(a) states “… Such substances shall be assigned to the substance group (if the substance group has a mandatory reporting requirement) or otherwise to the product part (if 4.2.2 applies) or otherwise to the product.”. Subclause 4.3.4(a) is similar. The key phrase is “assigned to the substance group”; however, there is no information or guidance in the IEC 62474 standard as to what is “ the substance group” for Lead sulfochromate yellow. You can’t necessarily jump to the conclusion that it is all declarable substance groups that have Lead sulfochromate yellow as a member.

Several possibilities for assigning the substance group arise; for example, the cation substance group could always be used (if applicable) or the anion substance group could be used. The substance group field in the declarable substance entry in the database could also be used to specify the substance group that should be used for the declarable substance; however, the substance group isn’t specified for most declarable substances in the DSL. Given that this situation was hypothetical at the time of writing the standard, there was reluctance to explicitly address this in the standard. The general intention, if this situation were to ever arise (which it has) was to let the responder (supplier filling out the material declaration) use their discretion to select the assignment of a declarable substance to a substance group.

So where’s the double reporting… the double reporting comes in because both declarable substance groups “lead/lead compounds” and “chromium (VI) compounds” must be declared. The Lead sulfochromate yellow substance declaration can only be assigned to one of these. If it’s assigned to lead/lead compounds, there is duplication in chromate mass because the current xml schema has no way to link the Lead sulfochromate yellow with the chromate substance group entry.