Technical Questions

What's the difference between an FMD and RCD?

The Regulatory Compliance Declaration (RCD) tool includes expert regulatory guidance on all substances which are restricted or declarable for hardware products by regulations in North America, Europe and Asia Pacific. But we don’t just list the Regulations. BOMcheck provides detailed practical guidance on where these substances can be found in materials or parts of hardware products, and any exemptions that apply. This saves time and costs for suppliers because if you know where to look for restricted and declarable substances, then you can reduce your sample testing costs. If the BOMcheck guidance and ‘quick fill statements’ indicate that a substance is not found in your parts (for example, because the substance is used as a plasticizer and your parts do not contain plasticizers) then you should follow the guidance and claim compliance for your parts for this substance. You should only consider sample testing for substances which the guidance indicates are likely to be found in your parts.

A Full Materials Declaration (FMD) provides the % weight of each individual material in the part and the % weight of each substance which is intentionally added to each material (i.e. no need to declare impurities in the material). For example, an FMD for a PVC coated copper wire will contain two materials – the PVC coating and the copper wire. The PVC coating will include all intentionally added substances (e.g. stabilisers, plasticisers, flame retardants etc).

Philips and other leading OEMs encourage you to make a Full Materials Declaration (FMD) because then you do not need to update your declaration every six months when more substances are added to the REACH Candidate List and other regulatory requirements.

BOMcheck uses your FMD to re-calculate an RCD for your parts when the list of regulated and declarable substances changes. The FMD tool includes over 524,000 chemical names, synonyms and trade names that you can choose from. BOMcheck shows you whether each substance is currently restricted or declarable or is included in an industry list such as GADSL, JIG, CMR Category 1 or 2, or ESIS PBT or vPvBT.

You can choose to make the FMD confidential to certain customers and allow other customers only to see the RCD which BOMcheck calculates from your FMD. For example, a plastics manufacturer can choose to allow certain customers to see the FMD for the plastic, but only allow other companies (e.g. the moulders) to see the RCD that BOMcheck calculates for the plastic.

What if my FMD has proprietary substances?

You must declare >95% of the substances in the FMD tool. You can have up to 5% proprietary substances. You do not need to enter the proprietary substances as a line in the FMD, BOMcheck automatically calculates the percentage of proprietary substances in each material.

What is the difference between a 1752A and 1752B XML?

IPC-1752B is the new industry standard for material declarations that includes all data required for SCIP submissions. IPC-1752A does not include all required fields for communicating SCIP required data and so is not sufficient for SCIP purposes.

Why is my 1752A Class C XML not uploading?

The most common reason for IPC-1752A Class C XMLs failure to upload is that they contain declaration data that indicates an SVHC is contained above the threshold. IPC-1752A does not contain the required fields for SCIP reporting purposes and so, BOMcheck does not support XML upload of IPC-1752A Class C XMLs if an SVHC is contained above threshold. To declare such parts, you must use the RCD/FMD tool to capture the mandatory fields for SCIP reporting.

Why can't I select multiple exemptions for my declaration?

BOMcheck no longer supports the selection of an exemption where the worst-case concentration exceeds the exemption concentration threshold when creating a Regulatory Compliance Declaration (RCD). For example, you will not be able to select exemption 6a-I (Lead as an alloying element in steel for machining purposes containing up to 0.35% by weight and in batch hot dip galvanised steel components containing up to 0.2% by weight) if the worst-case concentration of lead in your part is 3.9%.

Instead, you must make individual declarations for the two components using the two different exemptions and then use BOMcheck’s assembly tool to roll up the declarations for the overall compliance status.

How can I automate data download to my in-house IT systems using BOMcheck's API?

BOMcheck provides an open-ended API that Manufacturers can implement to automate the data download from BOMcheck to their in-house IT systems. See the guide ‘Guide to using the BOMcheck API to automate data download to in-house IT systems’ in the downloads section on SCN for further details.

How does BOMcheck deal with ITAR?

• You and your suppliers control the confidentiality of your RCD/FMD/Assembly details in BOMcheck
• You and your suppliers need to ensure that you use these confidentiality controls appropriately so that you do not give access to sensitive data under ITAR or the multi-Country Export Control Program for Dual-Use Goods & Technologies

Where can I find the US TSCA substances in BOMcheck?

You can find the US TSCA restriction under ‘Substances restricted or declarable by other legislation’ when creating a Regulatory Compliance Declaration (RCD) in BOMcheck.

The following US TSCA listed substances have not been added in BOMcheck:

• Decabromdiphenylether (DecaBDE), CAS 1163-19-5: DecaBDE is already covered in BOMcheck under RoHS under the same threshold as TSCA, therefore it has not been added again.
• 2,4,6-Tris(1,1-dimethylethyl)phenol (2,4,6-TTBP), CAS 732-26-3: The restriction on 2,4,6-TTBP only apply to chemicals, not supplied articles. Therefore, the restriction has not been added to BOMcheck.
• Hexachlorbutadien (HCBD), CAS 87-68-3: The uses of HCBD does not apply to supplied articles and so it has not been added to BOMcheck.
• Pentachlorbenzolthiol (PCTP), CAS 133-49-3: BOMcheck and the Substance List Working Group with inputs from IEC 62474 determined that PCTP is reacted during the rubber manufacturing process and is not present above the threshold in supplied articles. Therefore, PCTP has not been added to BOMcheck.

Why is there no effective date in assembly XMLs?

There are three date types tracked for declarations:

1. Date Added
2. Date Effective
3. Date Approved

The effective date is only applicable to discrete part declarations made by suppliers. As an assembly declaration is a roll up of discrete part declarations, the effective date is not applicable. The date provided in the Assembly PDF is the approval date which is the last date when the manufacturer creating or uploading a BOM approved this assembly. The approval date cannot be added to the XML as there is not attribute for it and these two date types should not be used interchangeably.