Issue link: https://iconnect007.uberflip.com/i/1166358
SEPTEMBER 2019 I PCB007 MAGAZINE 55 of REACH article 33) or any raw material de- livered with their SDS, a standard data sheet with 16 standardized sections as defined by the Global Harmonized System (GHS). It could be a sample for test laboratories to provide their report about its substance composition, or any specific products (like packaging or bat- tery) with specific reporting requirements. Declaring hazardous materials and substanc- es in a product could be done in several ways: • Declare if your product contains or does not contain some hazardous substances or materials targeted by the regulations; such a declaration called Regulatory Com- pliance Declaration (RCD) establishes the compliance of the product regarding a given regulation. This is typically what is used for EU RoHS regulations; the decla- ration should include the precise version of RoHS and optionally some exemptions that are relevant for the product – The main advantage of this type of compliance declaration is the protection of the manufacturer intellectual property (IP) with no communication for all of the materials and substances used in the products – Disadvantages are if the regulation changes (new restricted substances or materials, exemptions expire), manufacturer declarations have to be updated • Declare the materials and/or substances present in the product, either with partial material declaration (PMD) usually against a substances list (SL) or with a full material declaration (FMD). SL could be authored by any legal organization (either countries or groups of them, like the Europe Council) or trade associations representing the industry sectors. Sub- stance lists may specify the substance to be either prohibited or restricted for some applications (RSL) or just declarable (DSL) – The main advantage is that FMD does not require updates; partial material declaration is also stable for a given substances list – Disadvantages are providing substances composition could affect manufacturer IP. Tolerance could be accepted to hide some substances that are considered as confidential to protect the IP, only if those substances are not declarable against the regulations or the sector lists Manufacturers have access to various decla- ration types to achieve their regulatory man- dates or their customer requirements. Current Issues and Future Challenges One of the main issues for the product dec- larations exchange in the supply chains is that manufacturers communicate their declarations in portable document format. That causes a lot of burden in the companies to request, collect, store, update, and extract the content and use these paper forms or electronic portable docu- ment format files. One solution may be to use data exchange formats. Many spreadsheets, forms, or online tools are available for this, but the best option is to use data exchange formats as standard to exchange either compliance declarations or composition declarations for the products. The trend for the last 10 years is to use the XML language (eXtended Markup Language) for such standard. Data exchange formats, such as IPC-1752 and IEC 62474 XML standards (the most used), are already in use by manufacturers and their supply chains to exchange such declarations. Other XML standards are also available to cover specific needs: SDScomX - ML format used for communicating the SDS; IPC-1755 standard for conflict mineral dec- laration (CMD); IPC-1753 for laboratory re- port declaration; IPC-1758 for ship, pack, and packaging materials declaration; and the new IPC-1754 standard issued in May 2018 that al - lows declaring substances in products against any DSL (for instance, EU REACH Candidate List, or the aerospace and defense declarable substances list, AD-DSL) but also substances used in processes or process chemicals. Those substances are not present in the product put onto the market but may cause an obsoles -