Material Composition Declaration requirements were initially driven by regulations, ie European Union Restriction of Hazardous Substances (EU RoHS) and Waste of Electrical and Electronic Equipment (WEEE) etc. The EU ROHS and WEEE Directives apply specifically to electrical and electronic equipment (EEE). RoHS restricts the use of six hazardous substances (lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls and polybrominated diphenyl ethers) in EEE, and WEEE controls the disposal of such products. Barring the "Self Declaration" philosophy, there are no specific requirements for the application of a specific mark or testing by independent third parties. However, the authorities within each of the participating EU member states will carry out market surveillance and conduct checks on products. If a product is found to be non-compliant with the RoHS requirements, the manufacturers of such products will be asked to demonstrate that due diligence has been used and "reasonable steps" were taken to comply with the aforementioned Directives. This legal defense is used for other legislation, but as to what constitutes "reasonable steps" has not been accurately defined to date. In addition, with the authorization or the Restriction, Evaluation and Authorization of Chemical Hazards (REACH), ATCS needs to demonstrate that our products, which by definition are ARTICLES, do not contain any Substances of Very High Concern (SVHCs).
To demonstrate compliance, manufacturers of electrical and electronic equipment need to undertake extensive and time consuming surveys of their components and sub-assembly suppliers. In turn, first tier suppliers require materials information from their suppliers, and so on down the supply chain. The Material Declaration Tool (The Tool) has been developed to assist Amphenol TCS in complying with the litany of reporting requirements for material composition declarations.
The introduction of new materials/products and the rapid phasing out of existing products/material sets and is correspondingly increasing the possible permutations and combinations of products and materials. This is exponentially increasing the data management requirements, beyond the capabilities of conventional/rudimentary data management approaches. In addition, specific customer requirements, generating a pre-determined boiler plate declaration for each product becomes impractical, especially as reporting formats can change on a yearly (or faster) basis.
Amphenol TCS can provide material declaration report in any of the various industry and customer friendly formats including the IPC-1752, Compliance Connect or other customer specific forms for any approved part number. Please contact
ehs@amphenol-tcs.com with your company information and the Amphenol TCS Part Number.