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88 SMT007 MAGAZINE I JULY 2018 this regard—with only changes being to allow- able exemptions and additional documenta- tion requirements. Otherwise, the basic six restricted substances have stayed the same from its initial entry into force through its "Recast" in 2011. The next addition of four additional substances, per the European Commissions Delegated Directive 2015/863/EU, will enter into force July 22, 2019. However, custom- ers across the supply chain are already asking for data and compliance conclusions for these substances. This pre-enactment customer driven activity clearly demonstrates just how valuable FMDs can be since suppliers with FMD data can already satisfy their customer's requests about the presence of newly (and yet- to-be) restricted substances. Since RoHS exemptions have set expira- tion dates, it is also prudent to know what exempted substance is present, besides just knowing you are compliant with exemption but not exactly why. Since exemptions are substance-specific, this level of information is very useful as a warning that a noncompli- ance could develop when a product that was once acceptable to ship is no longer compliant because the exemption has expired! FMD data provides the ability to look ahead in time for exemptions that are set to expire, allowing the company to take early action through product redesign or finding alternate suppliers. REACH (Registration, Evaluation, Authori- zation and Restriction of Chemicals), promul- gated by a separate agency, ECHA (European Chemicals Agency), is much more dynamic and adds new substances of very high concern (SVHC) to the candidate list roughly twice a year ever since 2008. Figure 1 shows the number of substances added to REACH since its beginning in October 2008 through the last date as of this writing. Shorter gray bars count the substances added each date, with the larger black bars indicating the cumulative total of substances. Note there is some double counting in the Figure 1 data, since a few of the substances were listed a second time due to different toxi- cological reasons. Also, note that the count is based on just the primary list of SVHC posted by ECHA in its main table, but the actual indi- vidual substance count by CAS number is even greater if one consults the ECHA support- ing documentation. Further, it is noted that Amendment 3 of IPC-1752A, which is not fully Figure 1: Number of REACH SVHCs from 2008 to present. (Black bars = total; Gray bars = added each date.)

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