About Compliance Definitions

Compliance definitions are used to determine whether materials and parts are compliant.

This page discusses:

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
        • Material 1
      • Subtier Part 2
        • Material 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
        • Material 1
      • Subtier Part 2
        • Material 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
        • Material 1
      • Subtier Part 2 - Is Article=Yes
        • Material 2
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
        • Material 1
      • 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"
    • Part 1
    • Part 2
  • Product B, Application "Laptop"
    • Part 3
    • Part 4
  • Product C, No selected application
    • Part 5
    • Part 6

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"
    • Part 1
    • Part 2
  • Product B, Application "Laptop"
    • Part 3
    • Part 4
  • Product C, No selected application
    • Part 5
    • Part 6

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