Materials and Calculated Compliance

Materials Compliance Management uses thresholds, exemptions, flags, and component substances to calculate compliance for materials.

This page discusses:

If the material has component substances, the following logic is used:

  • The component substance references a substance that has a threshold defined for it in the compliance definition:
    • If the component substance references a compliance application that matches an exemption in the compliance definition, it is ignored.
    • If the compliance definition indicates that for a substance threshold that the "Intentionally Added - 0% Threshold" flag is set, and the substance reference is marked as intentionally added (an attribute of the Component Substance relation), then the reference to the substance is assumed to exceed the threshold of the compliance definition.
    • If the "Intentionally Added - 0% Threshold" flag is set, or the component substance is not marked as intentionally added, any Fill or PPM quantities are converted to %. The % quantities of the remaining references to the same substance are summed and compared to the substance threshold.
  • The component substance references a substance that in turn references a substance classification that has a threshold defined for it in the compliance definition:
    • If the component substance references a compliance application that matches an exemption in the compliance definition, it is ignored.
    • If the compliance definition indicates that for a substance classification threshold that the "Intentionally Added - 0% Threshold" flag is set, and a substance of that classification is referenced and marked as intentionally added (an attribute of the Component Substance relation), then the reference to the substance of that classification is assumed to exceed the threshold of the compliance definition.
    • If the "Intentionally Added - 0% Threshold" flag is set, or no component substances of that classification are marked as intentionally added, any Fill or PPM quantities are converted to %. The % quantities of the substances referencing the same substance classification are summed and compared to the substance classification threshold.

If the material has component materials, the calculated compliance of the component materials is queried. The calculated compliance of the material is set to "Yes" if substances exceed of the component a threshold in the compliance definition and none of the component materials have a calculated compliance of "No". Otherwise, the calculated compliance is set to "No".

Note: The "Threshold Type" attribute of a compliance definition determines the definition of "threshold exceeded". If "Threshold Type" is set to "Maximum Allowed" a threshold is exceeded if the amount is greater than the threshold value. If "Threshold Type" is set to "Minimum Rejected" a threshold is exceeded if the amount is greater than or equal to the threshold value.

Your Business Administrator can configure Materials Compliance Management to include or exclude product level compliance applications from compliance calculations in materials. When set to exclude, product level exemptions contained in materials are ignored when calculating compliance. When included, product level exemptions contained in materials are treated as material level exemptions when calculating compliance.

Compliance violations for a material are tracked to determine if taking a product level exemption makes a part compliant. A violation is defined as a substance or substance classification threshold that has been exceeded for a compliance definition. The violations are rolled-up to parents.

Compliance violations for a material or component threshold are tracked by the app through the components of the CEP. A threshold violation can be found in:

  • The FMD of a first article part or a material.
  • The declared thresholds of an MEP. The declared thresholds are used only when the MEP consists a compliance declaration and not a compliance composition.

A declared threshold for the violation is created as the following:

  • For the component level thresholds, the declared thresholds are created for the first articles, which are exceeded the thresholds.
  • For material level thresholds, the declared thresholds are created for every materials, which are exceeded the thresholds.
  • The rollups for ECHA material classifications to this level are also considered.

To result of this, the multiple declared thresholds are created for a threshold. For example, Lead in Batteries. But the app is supported to create declare thresholds for all the violations.

SCIP Data

If the exceeded threshold is for a component threshold in a first article and it is marked as a SCIP threshold, the SCIP information for the first article can be included in the declared threshold.

  • If the violation is found in the composition data (class D), the SCIP part information can be included from the part. The SCIP material classification information needs to be assembled from the materials that contribute to the violation (any material under the part at any level with the substance or substance classification causing the violation).
  • If the violation is found in the compliance data (Class C) of an MEP and the composition data is not present, the SCIP information can be included directly from the declared thresholds of the MEP.

The following examples, only the Article Category as a part SCIP attribute is displayed. But Primary Article ID, Article Name, Article Category, Production in EU, and Safe Use Instructions attributes are present.

Example 1 (Leaf subtier parts are the first articles)
P1
  • P2 - MEP1
    • ST1 (SCIP Art Cat = 1000010)
      • Matl 1, SCIP Matl Cls = Glass
        • Lead - 0.3%
    • ST 2 (Art Cat = 1000020)
      • Matl 2, SCIP Matl Cls = Steel
        • Lead - 0.2%
For P1, ST1 and ST2 are first articles. There are 2 material level violations and 2 component level violations. Lead component level threshold is also marked as SCIP, therefore, declared thresholds created for these violations also include SCIP data.

P1

  • Declared Thresholds
    • Lead - 0.3% - Component, SCIP Art Cat=1000010, SCIP Matl Cls=Glass
    • Lead - 0.2% - Component, SCIP Art Cat=1000020, SCIP Matl Cls=Steel
    • Lead Compounds - 0.3 – Material
    • Lead Compounds - 0.2 – Material

Example 2 (MEP is marked as the first article)
P1
  • P2 - MEP1
    • ST1 (SCIP Art Cat = 1000010)
      • Matl 1, SCIP Matl Cls = Glass
        • Lead - 0.3%
    • ST 2 (Art Cat = 1000020)
      • Matl 2, SCIP Matl Cls = Steel
        • Lead - 0.2%
    • ST 3 Matl 3, SCIP Matl Cls = Brass
      • Iron- 100%
For P1, MEP1 is first article. The material classifications for SCIP are assembled from Mat1 and Mat2 that both contain Lead and contribute to the violation.

P1

  • Declared Thresholds
    • Lead – Component - 0.4%, SCIP Art Cat = 1000030, SCIP Matl Cls – Glass, Steel
    • Lead Compounds - 0.3 – Material
    • Lead Compounds - 0.2 – Material

Note: The ST1, ST2, and ST3 are leaf components, therefore, the app applies the component level threshold to all 3 components. However, they are not the first articles and MEP1 is first article, the app only creates declared threshold for the component level violation at MEP1.

Example 3 (MEP1 has only the compliance data associated with it)
P1
  • P2 - MEP1
    • Declared Thresholds
      • Lead - 0.3% - Component, SCIP Art Cat=1000010, SCIP Matl Cls=Glass
      • Lead - 0.2% - Component, SCIP Art Cat=1000020, SCIP Matl Cls=Steel
  • P3 - MEP2
    • ST3 (SCIP Art Cat = 1000050)
      • Matl 1
        • Cadmium - 0.3%, SCIP Matl Cls = Copper
    • ST3 (SCIP Art Cat = 1000060)
      • Mat 2
        • Antimony - 0.4%, SCIP Matl Cls = Steel
For P1, MEP1, ST3, and ST4 are first articles. In this case, some of the declared threshold for P1 is included from the compliance data associated with MEP1 and the remaining data is included from the composition data associated with MEP2.

P1

  • Declared Thresholds
    • Lead - 0.3% - Component, SCIP Art Cat=1000010, SCIP Matl Cls=Glass
    • Lead - 0.2% - Component, SCIP Art Cat=1000020, SCIP Matl Cls=Steel
    • Cadmium - 0.3% - Component, SCIP Art Cat=1000050, SCIP Matl Cls=Copper
    • Antimony - 0.4% - Component, SCIP Art Cat=1000060, SCIP Matl Cls=Steel
    • Cadmium Compound - 0.3% - Material

Changes in SCIP Data

With the support for IMDS 13, there are some changes related to SCIP data when you create the SCIP data at the part, component, and material levels:

  • The app exports the SCIP data at part and material level whenever there are SCIP data is available.
  • IMDS does not support SCIP data on Semi-Component. Therefore, it is considered that the Semi-Components are never articles. During export, if a part is uploaded as Semi-Component, the app does not include the SCIP data.
  • Also IMDS does not require the SCIP data during upload. The default values are set for each item if there is no value. The table below contains default values for SCIP data.
    Field Description
    Article Category 8708999790 (Vehicles, aircraft, vessels and associated transport equipment > Vehicles other than railway or tramway rolling stock, and parts and accessories thereof > Parts and accessories of the motor vehicles of headings 8701 to 8705 > Other parts and accessories)
    Production in European Union No data.
    Safe Use Instructions Not required.
    ECHA Materials Category IMDS derives a category from the IMDS Material Classification.

Changes in the IMDS Ids to Support Multisource Components

Earlier, the app stores IMDS ids for internal equivalent on Manufacture Equivalent relationship. This setup is added to accommodate switching back and forth between internal equivalents. Now, this is updated to store IMDS ids for these modules on the EP. To switch between internal equivalents provide the result in an update (revised) of EP during subsequence upload.

Currently the IMDS ids are displayed for EP in the context of selected equivalent, if:

The selected equivalent is an external module, the app reads the IMDS ids from MEP and displays on properties page for EP.

The selected equivalent is an internal module, the app reads the IMDS ids from Manufacture Equivalent relationship and displays in the properties page for an EP.

Now, the IMDS ids are displayed on the part for which these are belong with:

If EP is uploaded with alternates, the IMDS ids are stored directly on EP and displayed in the properties page for an EP.

If EP selected equivalent is an external module, the there is no IMDS ids in the properties page for an EP. IMDS ids are displayed in the properties page of MEP.

If EP selected equivalent is an internal module, the IMDS ids are stored on EP directly and displayed in the properties page for EP.

To upload IMDS, the following are updates:

If EP is uploaded with alternatives, the app reads IMDS ids on EP.

Multi-Source option is selected as No: If EP selected equivalent is an external module and MEP has IMDS ids, the reference it.

Multi-Source is selected as No: If EP selected equivalent is an internal module, the IMDS ids are on EP itself. The app reads IMDS ids on EP. Earlier, the app reads the Manufacturer Equivalent relationship for internal module.

Multi-Source option is selected as No: If EP is make configuration, the IMDS ids are on EP, the app reads IMDS ids on EP.