Determining Compliance
Compliance is determined according to:
- A set of thresholds defined for
specific substances or substance classifications
- A set of exemptions that exclude a
component substance from being used to determine compliance
The types of compliance definitions used by areMaterials Compliance Management based on the thresholds defined:
Threshold Level |
Compliance Definition |
Part |
Contains at least 1 threshold with level =
Part |
Component |
Contains at least 1 threshold with level =
Component and no thresholds with level + part |
Material |
Contains only thresholds with level = Material
|
Compliance for parts, components, and materials is designated from worst to best:
"Out of Scope", "No", "Insufficient", "Contains Insufficient", "Unreported",
"Contains Unreported", "Yes with Exemptions", "Yes".
There are several uses of compliance definitions in Materials Compliance Management:
- If marked for rollup, causes a
calculated compliance to be computed for materials and parts.
- If selected for certain reports such as
the Scorecard and Substance Threshold report, determines the compliance of
materials and parts.
- If selected on the Export form, filters
the substances that will be exported.
When created, a compliance definition is assigned a policy of Enterprise (capable of
rollup) or User (does not roll up).
In addition to threshold values, a compliance definition includes the scope for
specific scope applications. The scope can be defined as one of these options:
- All
- Component Level - In Scope
Applications
- Product Level - In Scope
Applications
- Component Level - Out of Scope
Applications
- Product Level - Out of Scope
Applications
Whether the threshold for a part (component) or product is evaluated for compliance
is based on the compliance definition. For example, if a part is assigned a specific
scope application and the compliance definition specifies that scope application
with the scope is defined as Component Level - In Scope Applications, the threshold
is evaluated. For more examples, see Example Compliance Calculations.
Component Level Thresholds
When calculating part compliance using component level thresholds, the calculation
depends on whether the part is a first article.
A first article is defined as follows:
- Leaf parts in a BOM structure are
always treated as first articles for component level compliance
calculations. The BOM structure includes enterprise parts, equivalent MEPs,
and Subtier Parts. It is common for an MEP or Subtier Part to be the leaf
part and therefore be a first article.
- A higher level part in a BOM
structure is treated as a first article, if:
- Is Article = Yes for the
part
- Lower level parts in the
BOM structure do not have Is Article = Yes.
When evaluating compliance for Compliance Definitions that contain Component Level
Thresholds:
- Component Level Thresholds are
evaluated against the Articles using its Calculated Substances/Calculated
Substance Classification amounts.
- For items that are not first articles, the
compliance is inherited from its components.
Part Structure |
Explanation |
Part 1
- Part 2
- (MEP 1)
- Subtier Part 1
- Subtier Part 2
|
Subtier Part 1 and Subtier Part 2 are first articles because they are
leaf components and no higher level parts are marked with Is
Article = Yes. Component compliance for these parts is
calculated from Substance/Substance Classification amounts. MEP
1 inherits the worst case component compliance of Subtier Part 1
and Subtier Part 2. Part 2 inherits the component level
compliance of MEP 1. Part 1 inherits the component level
compliance of Part 2. |
Part 1
- Part 2
- (MEP 1) - Is Article=Yes
- Subtier Part 1
- Subtier Part 2
|
MEP 1 is marked as Is Article = Yes. Since no lower level parts are
marked with Is Article = Yes, MEP 1 is a first article. The
component level compliance of MEP 1 will be calculated from
Substance/Substance Classification amounts. Part 2 inherits the
component level compliance of MEP 1. Part 1 inherits the
component level compliance of Part 2. |
Part 1
- Part 2
- (MEP 1) - Is Article=Yes
- Subtier Part 1- Is Article=Yes
- Subtier Part 2 - Is Article=Yes
|
Subtier Part 1 and Subtier Part 2 are marked as Is Article = Yes.
Since no lower level parts are marked with Is Article = Yes,
these parts are first articles. MEP1 is also marked as Is
Article = Yes, but this part will not be treated as a first
article because it references child parts marked with Is Article
= Yes. Component compliance for Subtier Part 1 and Subtier Part
2 is calculated from the substance/classification amounts. MEP 1
inherits worst case component level compliance of Subtier Part 1
and Subtier Part 2. Part 2 inherits component level compliance
of MEP 1. Part 1 inherits component level compliance of Part
2. |
Part 1
- Part 2
- (MEP 1) - Is Article=Yes
- Subtier Part 1 - Is Article=Yes
- Subtier Part 2
- Material 2
|
Subtier Part 1 is marked as Is Article = Yes. Since no lower level
parts are marked with Is Article = Yes, this part is a first
article. MEP1 is also marked as Is Article = Yes. Even though it
references Subtier Part 1 which is marked as Is Article = Yes,
it also references Subtier Part 2 which is not marked as Is
Article = Yes. Therefore, it will also be treated as a first
article. Component level compliance for Subtier Part 1 is
calculated from substance/classification amounts. Component
level compliance for MEP 1 is also calculated from
Substance/Classification amounts. Part 2 inherits component
level compliance of MEP 1. Part 1 inherits component level
compliance of Part 2. |
Exemptions
The chemSHERPA v2.00 tool now allows suppliers to choose one or more
exemptions for a compliance type such as EU RoHS in the Composition
section.
Materials Compliance Management allows more than one exemption to be chosen for
a substance in a material. The chooser allows you to select multiple exemptions, and
the import and export functions properly import or export the multiple
exemptions.
New RoHS Exemption Codes
The chemSHERPA v2.00 tool supports new RoHS exemption codes.
Materials Compliance Management maps the 2.x exemption code to a single
application, and a 1.x import code could be mapped to the same application. For
export, some 1.x codes are not supported in 2.x, and the export function maps the
old application to a specific 2.x code already used by another application. This
mapping can result in 2 or more applications in Materials Compliance Management
mapping to the same 2.x code in the export.
To handle this situation, Materials Compliance Management adds
use="2x-export" or use="2x" to
the alias file. 2x-export means that alias can only be used
for export, and 2x means that alias can be used for import or
export.
Compliance Calculations for Compliance Processes
If a compliance definition is marked for process, Materials Compliance Management calculates part process compliance.
Each compliance process has its own rollup information and compliance value. When
calculating the compliance for a compliance process Materials Compliance Management uses the same method as used for a leaf part.
The calculated substances and substance classifications are defined as unknown.
Calculated weight does not apply to processes.
Compliance Calculations for Component Level
If a compliance definition is marked for component level, Materials Compliance Management calculates parts that are marked as IsArticle =
Yes and the by default, marked as IsArticle = Yes.
Earlier component level compliance calculation is calculated for the parts that are
marked as IsArticle = Yes and the by default, marked as IsArticle = Yes. But now it
is calculated according only to the first article.
The parts that are above the first article level inherits compliance from the child
parts below them. Though the part is marked as IsArticle = Yes, and the first
article is below to it, the part compliance is inherited.
Compliance Definitions for Data Management Types
The Owner or Compliance Administrator should review
compliance definitions that are used. The Materials Compliance Management setup allows you to choose the type of data
management to use.
These data management options can co-exist or stand alone.
Data Management Type |
Description |
RoHS Data Management |
RoHS data management includes a basic template
of the RoHS compliance definition based upon the EU RoHS
legislation. However, it is recommended that ALL customers work
with third party Environmental Compliance Legal Consultants to
provide guidance on the legal responsibilities for your company.
RoHS Data Management uses these five compliance definitions: EU
RoHS, Korea RoHS, China RoHS, JIG A, and JIG B. Any manufacturer
doing business in Europe must analyze their products for EU RoHS
and JIG compliance. |
ELV Data Management |
ELV data management defines the IMDS
compliance type, substance classifications, and compliance
definitions. For defining substance classifications, GADSL is
used. For compliance definitions, GADSL and ELV are used.
|
Packaging |
Packaging includes two compliance definitions:
EU Packaging and US Packaging. Both definitions are based on
directives that restrict the use of heavy metals in packaging
materials. |
REACH |
REACH data management includes compliance
values for EU REACH and EU REACH XIV. |
JAMP AIS |
JAMP AIS is used in combination with RoHS or
ELV data management options. |
Example Compliance Calculations
These examples show how compliance is determined based on the compliance
definitions.
Example: Component Level - In Scope Applications
Compliance Definition CDEF-A is defined as follows:
- Scope Application = Batteries
- Scope = Component Level - In
Scope Applications
Part structure and defined applications:
- Part 1
- Part 2, no defined
application
- Part 3, Application
"DVD Player"
- Part 4, Application
"Batteries"
Compliance calculations:
- Part 1: in scope based on the
value inherited from child Part 4
- Part 2: out of scope
- Part 3: out of scope
- Part 4: in scope
Example: Component Level - In Scope Applications
Compliance Definition CDEF-B is defined as follows:
- Scope Application = Batteries
- Scope = Component Level - In
Scope Applications
Part structure and defined applications:
- Part 1, Application "Batteries"
- Part 2, no defined
application
- Part 3, Application
"DVD Player"
- Part 4, no defined
application
Compliance calculations:
- Part 1: in scope
- Part 2: out of scope
- Part 3: out of scope
- Part 4: out of scope
Example: Component Level - Out of Scope Applications
Out of scope calculations exclude component Parts that have a defined application.
Compliance Definition CDEF-C is defined as follows:
- Scope Application = Batteries
- Scope = Component Level - Out
of Scope Applications
Part structure and defined applications:
- Part 1
- Part 2, no defined
application
- Part 3, Application
"DVD Player"
- Part 4, Application
"Batteries"
Compliance calculations:
- Part 1: in scope based on
having child parts that are in scope
- Part 2: in scope
- Part 3: in scope
- Part 4: out of scope
If the application for all the Parts was "Batteries," the Product level would be
out of scope for compliance calculations.
Example: Product Level - In Scope Applications
Compliance Definition CDEF-D is defined as follows:
- Scope Application = Plasma TV
- Scope = Product Level - In
Scope Applications
Product structures and defined applications:
- Product A, Application "Plasma
TV"
- Product B, Application "Laptop"
- Product C, No selected
application
Compliance calculations:
Product or Part |
Calculate Value |
Displayed Valued |
Product A |
Yes |
Yes |
Part 1 |
Yes |
Yes |
Part 2 |
Yes |
Yes |
Product B |
No |
Out of Scope |
Part 3 |
Yes |
Yes |
Part 4 |
Yes |
Yes |
Product C |
No |
Out of Scope |
Part 5 |
Yes |
Yes |
Part 6 |
Yes |
Yes |
Example: Product Level - Out of Scope Applications
Compliance Definition CDEF-E is defined as follows:
- Scope Application = Plasma TV
- Scope = Product Level - Out of
Scope Applications
Product structures and defined applications:
- Product A, Application "Plasma
TV"
- Product B, Application "Laptop"
- Product C, No selected
application
Compliance calculations:
Product or Part |
Calculate Value |
Displayed Valued |
Product A |
No |
Out of Scope |
Part 1 |
Yes |
Yes |
Part 2 |
Yes |
Yes |
Product B |
No |
Yes |
Part 3 |
Yes |
Yes |
Part 4 |
Yes |
Yes |
Product C |
No |
Yes |
Part 5 |
Yes |
Yes |
Part 6 |
Yes |
Yes |
|