Managing material declarations can be challenging and time-consuming. To facilitate this endeavor industry-wide, the International Electrotechnical Commission (IEC) devised IEC Standard 62474 to build a framework for business-to-business (B2B) communications regarding material declarations.
Even for supply chain manufacturers reticent to reveal trade secrets through material declarations, IEC 62474 provides mechanisms to meet regulatory requirements while protecting IP. Designers looking to engage in a more involved examination of their PCB materials supply chain can use IEC 62474 as a basis for communication with their suppliers, vendors, and chemical processors.’
An Industry Standard for Material Declarations
IEC 62474 assists the electrotechnical industry (e.g., PCBA manufacturing) by establishing reporting for material declarations that make transferring information requests between different supply chain members more efficient. Critically, material declarations are not a one-size-fits-all approach, as certain suppliers or sub-manufacturers may wish to conceal material trade secrets through confidentiality so long as these materials are neither queried by customers nor regulated.
Types of Material Declaration Forms Defined by IEC 62474
| Compliance | A product-level breakdown of the materials that match the IEC 62474 declarable substance list (DSL). |
| Composition | A more detailed part-level declaration report matches individual product substances to the DSL. |
The difference between these two boils down to whether a request for material declaration aims to meet compliance requirements set by law or assess when declarable substances are above threshold limits. For example, REACH substances of very high concern (SVHC) exceeding 0.1% of the final product composition by weight are subject to customer notification for safe-use handling and disposal.
IEC 62474 also offers suppliers and sub-manufacturers a framework for disseminating material declarations either through a generalized document or on an individualized basis.
Types of Material Declarations
| Distribution | The supplier furnishes a material declaration about their product(s) to a customer; this format allows the supplier to select how they wish to format their material declaration (assuming that they follow all regulations and necessary declarations). |
| Query | The requester determines the type of material declarations the supplier provides. The customer has more control over the declaration, but the supplier can still restrict non-regulated confidential material information if it is not explicitly requested. |
There are three specific criteria IEC 62474 applies to substance categorization:
- Grouping of substances according to relevant chemical regulations.
- Grouping of substances according to regulations without a defined reference date.
- Grouping of substances for industry-specific requirements.
The Scope of IEC 62474
The type of agreement between customer and supplier can vary according to IEC 62474, and the material declarations can contain varying levels of organization information. In terms of hierarchical format, the material declaration is a superset of product information and can include any of the following:
- Business information – general information related to the business, such as name, contact details, etc.
- Product information – data related to the product’s operation, functionality, or performance about material properties.
- Compliance declaration – specifies the information necessary to asses compliance with industry standards or government regulations.
- Composition declaration – includes a breakdown of the product, including all sub-products, on a material basis (up to and including homogenous materials).
- Material class declaration – specifies optional material class declaration information.
- Query list – a true/false response by the supplier or sub-manufacturer to material inquiries filed by the customer.
- Attachments – supporting documentation necessary for the material declaration.
It’s important to understand that the mere presence of restricted or regulated substances does not mean a product is unfit for production. Some material bans are regional, and application exceptions exist. IEC 62474 functions as a compliance-analysis aid, and even products that fully meet any material regulations/restrictions still require a conformity check.
Additionally, while IEC 62474 provides the necessary framework for supply chain declarations up to a full material disclosure (FMD), some additional exemptions (like those found in RoHS) may not fall within the scope of the FMD. Declarations may be optional; however, declared exemptions require a similar description level to ensure complete disclosure of data.
VSE Stays On Top of Full Material Disclosures
IEC 62474 ensures the smooth transfer of material declaration data between organizations so that business partners can make better-informed decisions about their supply chain sourcing. More importantly, proper maintenance of IEC 62474 information makes it easier for manufacturers to meet industry and government regulations without interruptions to production, sourcing, recalls, fines, and other financial burdens that can reduce profitability and delay time-to-market.
At VSE, we’re well acquainted with health and environmental compliance requirements; we maintain a broad database of material declaration information from leading vendors and material suppliers. Our engineers are committed to building electronics for our customers, and we’ve been realizing life-saving and life-changing devices for over forty years.
