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The Client is a company that offers hardware solutions with low-to-high volume manufacturing and integration test capabilities. Their wide range of products and services encompasses industrial, automotive, aerospace/defense and military, computing/communication, medical and other markets. With their facilities in USA, Mexico and Asia, the Client provides seamless service to customers across the globe.

The Client had been in the process of developing 12 different products that were to be supplied to their European customers. Prior to delivering them to their customers, the Client had to ensure that the compliance requirements were met as per the European Union compliance directive for RoHS and REACH.

The Client approached �ۿ۴�ý for support in meeting the EU RoHS & requirements. �ۿ۴�ý performed initial BOM validation, followed by a collection of the required compliance data and Certificates of Compliance (CoC) from the Manufacturers of the parts used by the Client in the 12 products.

�ۿ۴�ý’s Head of Compliance Solutions services said, “�ۿ۴�ý’s systematic approach and expertise in the field has undoubtedly encouraged the Client to make their decision in favour of awarding the project to us. Our team has experience in handling similar projects and is able to efficiently identify the customer’s exact needs and provide a suitable solution. Our expertise in direct sourcing of information from Manufacturers, maximizes parts coverage and reduced any gaps in compliance.”

About �ۿ۴�ý:

�ۿ۴�ý Engineering (enventure.com) is a privately-held, ISO 9001:2008 certified engineering solutions company, with full-fledged delivery centers in India. �ۿ۴�ý has been serving clients in North America and Europe since 1997 and is today a preferred supplier of engineering and master data management services to Fortune 500 companies, across different industry verticals such as hi-tech electronics, oil & gas, water treatment, automotive and industrial manufacturing. �ۿ۴�ý provides a wide variety of services to Clients, in areas such as Plant Design Engineering, Building Engineering, Product Design, Mechanical design, Technical Documentation, Component Engineering, Environmental Compliance Support and Master Data Management.

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The electro-technical industry and various companies associated with it make use of material declarations for tracking and declaring specific information regarding the material composition of the various final products. The new international standard of IEC 62474 aims to harmonize the requirements of various members within the supply chain and also improve economic efficiencies.

The role of new standard IEC 62474

To synchronize the requirements across the industry and to reduce the cost of data management, IEC has come up with a new standard called IEC 62474. This standard can act as the basis of data exchange for material composition data and provide material declarations.

IEC 62474 specifies: Material declaration content, including terms of substances, substance class and material groups. It also provides data standards for software developers to create applications to manage this data.

Information offered in the IEC 62474 database

There are four types of information provided in the IEC 62474 database

• Declarable substance groups and declarable substances:   This section contains substances and substance groups with information like “reportable applications”, “reporting threshold” and “reporting requirement”
• Reference Substances: This section contains an indicative list of specific substances that are included with in the substance group. This list is an informative list and not an exhaustive one.
• Material classes: This list includes designated material classes that need to be included in material declarations, if contained in the product.
• XML schema for materials declaration: In this category an XML schema and developer table is available for download.

Getting material declarations for the entire product Bill of Material is an important activity in the compliance effort of most companies. IEC 62474 is a step forward to support the mammoth task undertaken by companies every year to conform to the Environmental Compliances.

What are the substances that should be declared?

The substances that form a part of the products manufactured in the electrical and electronics industry should be mentioned or declared in this material declaration file as set according to the IEC 62474 standard. The manufacturing chemicals or substances that react and form other chemicals and/or otherwise do not continue to remain within the product are not needed to be reported. Nevertheless, in certain cases, a chemical reaction once started may not reach completion and traces of some unreacted quantities of any intermediate chemical substance may continue to remain within the finished product. Such chemicals must be reported at all circumstances. If the intermediate chemicals are presented in the declarable substances list of IEC 62474 and quantity of this component remains above reporting threshold in final product, then that needs to be included in the report. If that is not done, then the material declaration is not going to be in compliance with the requirements of IEC 62474.

A user may simply state that their firm within the is compliance with the norms as presented by the IEC 62474 provided they have included in the list all the reportable substances and the varied substance groups which are present within the final product in quantities above the final reporting threshold.

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RoHS, WEEE and REACH EU regulations don’t just affect companies based within Europe – they affect any company trading with the European Union. What is more, many other markets are now governed by laws related to those within the EU. RoHS and REACH compliance have become global issues, making environmental compliance management mandatory for engineering firms, even those trading at a local level.

When considering environmental compliance management, you have to consider world conflict and political issues, as well as the harm your products may be doing to the environment. For example, is your company guilty of using conflict minerals? This has nothing to do with the REACH directive, but with the Dodd–Frank Wall Street Reform and Consumer Protection Act, which was signed by President Obama in July 2010, and came into effect in April 2011.

The Act called for a sweeping reform of the US financial regulatory system, which among other things required that any company listed on the US Stock Exchange must declare any Conflict Minerals mined in the DRC zone. In other words, any minerals mined in the Democratic Republic of Congo, and adjoining African countries suffering armed conflict.

With so many global mandates now in force, many engineering companies are turning to us at �ۿ۴�ý Technologies. We offer a comprehensive range of environmental compliance services which cover everything from to the Dodd–Frank mandate.

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Unlike RoHS, WEEE and REACH, the ELV directive is specific to automotive engineering. However, with ASIC and VLSI designs being integral to modern automotive engineering, it has an impact on many electronic and component engineering firms, both in the EU and globally. Like the directive, ELV compliance has been adopted across the world, with most countries on the global manufacturing platform having their own versions in place.

The GADSL (Global Automotive Declarable Substance List) is intrinsically linked to both the ELV directive and the IMDS (International Material Data System), which was established in response to the directives being put in place. The was established by OEMs in order to establish a global tracking and logging system for materials being used in automotive parts and accessories. It requires that all parts and components used in automotive assemblies and sub-assemblies list the chemicals used in their manufacture. The lynchpin of this is the GADSL, which is a list of all prohibited and declarable substances used in automotive applications, together with threshold limits.

If you engineer mechanical or electronic components for the automotive industry, these rules affect you. We at �ۿ۴�ý Technologies offer environmental compliance solutions for all engineering sectors, with particular expertise in the area of GADSL and ELV compliance.

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As technology becomes ever more advanced, so products go out of circulation that much quicker. Part obsolescence management (OM as it relates to individual products and components) is an essential area of engineering today. You only have to look at the obsolete semiconductor lists to realize that.

Component manufacturers make a lot of money by placing a finite lifespan on semiconductors, often far shorter than that experienced in use. Without effective obsolescence management tools, engineers can be left high and dry when, eventually, components do wear out – it’s not uncommon for replacements to be incompatible with the originals.

The way to avoid this is by ensuring your plan incorporates reliable lines of communication between you, your OEMs and your customers, so product change notification (PCN) alerts are announced, before they’re imminent, to every member of the supply chain – including the end user. Don’t forget, obsolescence is not controlled by market forces alone. Environmental compliance laws, for example EU RoHS and REACH regulations, come into it as well. Even if a component is currently exempt, an update to the law could change that.

The rules are simple: an effective master data management plan which links engineering BOM (bill of materials) and environmental compliance data to a central database, with regular data cleansing to ensure records are kept uncluttered and up-to-date. We at �ۿ۴�ý Technologies offer an extensive range of enterprise data management solutions, from BOM scrubbing to .

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The problem with omitting lead from tin solders is that, in its absence, spontaneous crystalline ‘whiskers’ can form. Electrically conductive, they can take anything from a few days to several years to develop, and sometimes (no one knows why) don’t grow at all. They can bridge contacts, short electrical circuits, and bridge traces, and no printed circuit board or VLSI design is exempt. In a piece of military (or civil) avionic hardware, the results can be catastrophic.

There is currently no fail-proof way to test the susceptibility of new PCB designs to whiskering, no way of predicting its occurrence, and no guaranteed prevention, except a minimum 3% lead addition. Many of the hardware systems using embedded firmware – for example, military applications – are exempt from environmental legislation. However, in a predominantly OTS (off-the-shelf) industry, component manufacturers aren’t prepared to start making specialist one-off products. It costs them money.

Can we live without lead solders? It seems we may have to. The race is on to find suitable alternatives, but in the meantime, those still using traditional lead-containing components will find them harder and harder to obtain. Part obsolescence management and PCN alerts are just two of the solutions we at offer, to help you cope with problems caused by environmental compliance.

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REACH legislation governs the import and production of chemical substances within the EU. Certain products produced for the defence industry are exempt. However, exemption decisions were very much made on a national basis, and varied between member states. It became obvious to the EDA (European Defence Agency) that REACH compliance required a more harmonised approach. Creating a transparent, open European Defence Market aligning national exemption policies would considerably simplify matters for component manufacturers and other producers, not least those wishing to export into the European Union.

In March 2010, the pMS (participating Member States) of the EDA agreed a Steering Board Decision which set common standards for REACH exemptions in the defence industry. A public web portal was also established to provide transparency over national policies and procedures. The PMS are now in the process of adopting the new international standards, which will be reviewed annually starting in 2011.

In realisation of the fact that the affects non-member countries of the EDA, such as the US and Canada, the Steering Board invited these “third member” states to adopt the new REACH legislation principles, further harmonising the process of supply.

The Steering Board decision is a promising development in a controversial and confusing area. We at �ۿ۴�ý Technologies offer a number of solutions to help you cope with the complexities of ROHS, WEEE and REACH legislation.

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