Improving the safety of electronics benefits users and the environment. With the rapid increase in electronic waste heading to landfills at the end of the 20th century, lawmakers introduced and adopted new regulatory mechanisms to reduce the prevalence of the most dangerous substances found in electronic devices. Manufacturers have had to grapple with continued research into material safety while consumers have become increasingly cognizant of their purchases’ environmental and potential health risks. Full material disclosures – a method of logging and tracking material usage throughout the supply chain – allay concerns and keep manufacturers ahead of changes to material restrictions.
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Full Material Disclosures Track Supply Chains
A full material disclosure accounts for the contents, composition, and concentration of all materials found within a product. The focus of the full material disclosure is on homogenous materials. However, definitions differ between regulatory standards: REACH uses mechanically inseparable materials (meaning REACH evaluates products at the article level), while RoHS defines homogeneity as uniform material composition. The primary challenge for manufacturers needing to maintain material disclosures is to account for the supply chain above them, as substances without prior tracking efforts can take a year or longer to categorize correctly.
Meeting regulatory requirements for electronics manufacturing can be difficult when a significant portion of the bill of materials (BOM) includes electronic components whose own disclosures may be challenging to track down, incomplete, or otherwise unsatisfactory in fully describing the material contents. While it’s fair to assume that most components from reputable manufacturers meet industry standards, the core issue is that some regulatory standards like REACH have threshold and percent limits for the total assembly. While individual components may pass requirements, the combined components within the PCBA may not. Therefore, assemblers must be able to incorporate the component manufacturer’s compliance information for a complete material disclosure.
Regulations set threshold limits rather than outright bans on some hazardous materials to facilitate manufacturing and supply chain sourcing flexibility. These exceptions must always conform to scientific studies on humans, the environment, and ecology. For example, REACH outlines substances of very high concern (SVHC) that cannot exceed 0.1% by weight of the final assembly. While some may see the limit as excessively strict, a threshold (as opposed to an outright ban) gives manufacturers more leeway.
It’s worth noting that some manufacturers view full material disclosures with trepidation. Some materials may remain unreported due to their presence in IP-protected processes; if they later become reportable, all relevant documentation will require an update. Process chemicals completely consumed during reactions still demand reporting, even if they are undetectable in the final product. This conflicting nature of the material “contents” of the product can be a source of confusion for customers that damages a product or company’s image. Finally, full material disclosures for the same component when sourcing from multiple vendors or suppliers (often necessary when optimizing cost and lead times) may provide different declaration levels, meaning the disclosure is only as good as the least detailed reporting.
Building the Framework for Material Disclosure Information
While RoHS, REACH, and similar restrictions provide the impetus for full material disclosures, none of these regulations deal with the framework of how manufacturers and suppliers log, store, and share material information. For this, IPC and IEC devised multiple industry-specific and nonspecific standards. First, IPC-1752A defines four levels of material disclosure:
- Class A is the most basic level of declaration, where the manufacturer simply states whether their product meets a defined query list.
- Class B includes any information on substances intentionally added to the product, including substances present at a level above thresholds.
- Class C provides a product-level declaration based on a cross-reference between JIG-101 and REACH.
- Class D offers a full material disclosure of the product materials at the homogenous level, i.e., a list to the precision that none of the materials are mechanically separable or have variable material composition.
Other material compliance standards help simplify inter-organizational compliance efforts:
- IPC-1754 exclusively focuses on the aerospace and defense industries; data exchanges account for chemicals used during production, operation, maintenance, repair, or replacement.
- IEC 62474 acts as a standard database for industry exchange. By supporting the framework of material disclosure protocol and data transfer/processing, IEC 62474 makes it easier for manufacturers to look up material information from collaborating component suppliers. The database improves adherence to national and global standards while reducing the risk of penalties associated with non-compliant product materials. Indirectly, the standard supports innovation in materials engineering by promoting safe or safer materials that reduce the incidence of hazardous substances. It’s worth noting that since manufacturers maintain the database voluntarily, material information can be missing.
Your Contract Manufacturer Maintains Material Disclosures So You Don’t Have To
Full material disclosures require maintenance and upkeep but also help manufacturers stay on top of changes to industry regulations. As an added benefit, engaged customers looking to minimize the environmental footprint of their purchases can view supply chain transparency as a selling point. For designers working on new product introductions or overwhelmed by the process of detailing an extant supply chain with a full material disclosure, VSE is here to help. Our engineers are committed to building electronics for our customers, which includes leveraging our extensive supplier tracking database. We’ve been realizing life-changing and life-saving devices with our manufacturing partners for over forty years.
