Product compliance requires supply chain transparency. Here is how OEMs can achieve this.

Changes to the EU Restriction of Hazardous Substances (RoHS), EU REACH, and U.S. Conflict Minerals regulations make the need for supply chain transparency more crucial than ever. The European Court of Justice (ECJ) ruled in 2015 that the 0.1% threshold for notifying users about REACH SVHCs (Substances of Very High Concern) in articles applies to “each of the articles incorporated as a component of a complex product” rather than to the assembled end product. Many RoHS exemptions expired in the summer of 2016, marking the end of a long quest by original equipment manufacturers (OEMs) to understand how their products were affected and find suitable substitutes and replacements for critical sourced components.

The only way for OEMs to stay ahead of the increasing requirements of the “regulation curve” is to have complete information on all materials and substances in each component used in their products. Full material declaration (FMD) is quickly becoming the gold standard data requirement needed by an OEM to accurately assess the risk of restricted materials in a product. This means that supplier’s must provide a complete material and substance breakdown of their component/product in a manner that puts the least impact on their core business activities and enables the OEM to collect and aggregate similar information from other suppliers.

Regulatory agencies, customs declarations, international trade regulations and ultimately customers are requiring some form of objective “3rd Party” evidence that declarations of compliance (DoCs), FMDs (e.g. IPC 1752A) and OEM Product Certifications are accurate. One of the best methods for an OEM to confirm the material content of sourced parts is to require that certified lab reports from independent laboratories be provided by each of their component suppliers. To ensure that the material content and supplier lab reports are accurate, the OEM may also contract with a certified lab of their own choosing for a product level lab report. This provides multiple levels of objective proof for product certification. A primary cost/benefit justification for certified lab reports is to avoid fines, penalties and loss of business that would be incurred if the OEM product is found to contain dangerous, hazardous or restricted substances. Extreme examples of this have been demonstrated by cases in which excessive mercury has been found in skin products and melamine that was discovered in baby formula, both of which have resulted in a complete ban of the products and loss of revenue for the OEMs and distributors.

In a global market environment that requires a competitive edge to succeed — Halogen Free, WEEE, RoHS, REACH, Green and CE — are just some of the certifications that can give an OEM’s product that edge. The key question that must be answered with absolute certainty: How do we know what’s in our product? Practice has shown that one of the best answers to this may be found in certified lab testing and reporting.