1. Challenges and Methods for Standardised Legal Compliance
Management in the Production of Electronics
Marek Stachura*1
, Nick Stein1
1
KERP Center of Excellence Electronics & Environment, Vienna, Austira
* Corresponding Author, marek.stachura@kerp.at, +43 1 272 0370 14
Abstract
Legal frameworks that govern usage of substances in electronics manufacturing have been growing in complexi-
ty. There is strong interest within the industry for standardization of reporting structures and the streamlining of
data exchange procedures. While internationally recognized compliance regulations, standards and company-
specific indicators are emerging, their complexity calls for sophisticated data management and legal background
knowledge. Companies are struggling to fulfil the multitude of requirements.
This paper gives a short overview about the relevant regulations, and summarizes the new standards that have
been developed by the International Electrotechnical Commission (IEC). Challenges are identified and interpret-
ed from the view of a practitioner; and a software-supported approach to information management is introduced.
This approach allows for automated process management, data exchange and automatic report generation, ena-
bling time-saving across whole business processes.
1 Current Situation
Production companies usually operate in a global
market, therefore they need to meet different require-
ments throughout the different regions of the world,
countries or districts (e.g. REACH and RoHS in Eu-
rope, China/Japan RoHS and REACH adaptations in
Asia, the Toxic Substances Control Act in the USA
etc.). This demands a huge effort through the introduc-
tion of the essential and usually very specific
knowledge on one hand (interpretation and fulfilment
of the legal requirements), and on the other hand mas-
sive data flows (such as material data exchange for
product structures with a highly expanded supply
chain). In addition, companies are under market pres-
sure to streamline their operations and improve cost-
efficiencies in order to remain competitive (shortening
time-to-market and lower prices margins). The bal-
ance between the very complex (and increasing) legal
requirements and the market pressure increases the
risk that compliance with the law, for some products
will not be secure enough. The risk of regulatory non-
compliance increases over time, as the regulations are
not static, but continuously developed and adapted
(e.g. regularly extension of the SVHC-list of
REACH). For these reasons, manual processing com-
pliance data is not feasible.
Only now are standards regarding material declaration
data exchange in the supply chain emerging. This is
the same for software tools that consider the issue of
legal compliance for products. Both are focused on
attempting to solve the problem of data exchange with
varying degrees success.
2 Short overview of the legal re-
quirements
Global regulations around the usage of materials and
substances are still quite varied and in the most not
harmonized. This unfortunate situation is likely going
to be prevalent for a long time. Nevertheless, certain
trends in the global markets can be observed. The Eu-
ropean Union plays a precursory role in worldwide
environmental regulations. Many countries and world
regions are adapting their legal framework to the Eu-
ropean regulations. This process has happened with
the regulations that currently dominate the industry.
Following are the main legal acts, listed with brief ex-
planations:
 REGULATION (EC) No. 1907/2006 (EU-
REACH): Regulation on Registration, Evalua-
tion, Authorisation and Restriction of Chemi-
cals. Imposes on industry the responsibility for
assessing and managing the health risks of
chemicals and providing appropriate safety in-
formation to users. In parallel, the European
Union can take additional measures on highly
dangerous substances, where there is a need for
complementing action at EU level.
 DIRECTIVE 2002/95/EC (EU-RoHS): Re-
stricts the usage of heavy metals such as lead,
mercury, cadmium, and hexavalent chromium,

2. as well as flame retardants such as polybromin-
ated biphenyls (PBB) or polybrominated diphe-
nyl ethers (PBDE) and requires substitution to
safer alternatives in electrical and electronic
equipment.
 DIRECTIVE 2011/65/EU (EU-RoHS recast):
Revision of the RoHS Directive. The substances
covered remain the same, however the rules of
the first version of RoHS are extended to a much
wider range of products (e.g. to all electronic
equipment, cables and spare parts) and connects
the fulfilment of the RoHS requirements with
those of the CE-marking.
 China New Chemical Substance Notification -
MEP Order No. 7 (China REACH): Similar to
EU REACH; adopts several principles and con-
cepts of the European regulation. The most no-
table differences existing between EU- and Chi-
na-REACH are in the registration scope and
testing requirements.
 Administration on the Control of the Pollution
caused by Electronic Information Products
(China RoHS): Requirements apply to the same
substances like EU-RoHS, however the scope,
further responsibilities, exemption regulations
and product labelling are different. Implementa-
tion will be carried out in two phases.
 US Toxic Substances Control Act (TSCA):
Regulates the introduction of new or already ex-
isting chemicals. In addition to regulation of
new substances, it also includes existing chemi-
cals (in contrast to the EU-REACH regulation).
The list of adequate laws worldwide is much longer
(adequate and further regulations are defined in other
countries and regions), but the examples mentioned
clearly illustrate the scale of the challenge. Only now
are industry and international approaches trying to
standardize responses to these requirements.
3 First standardization approach-
es for material declarations
Standardized reporting structures and streamlining of
data exchange procedures can significantly increase
the efficiency of securing a product’s legal conformity.
It is no surprise that the first standardization ap-
proaches were carried out by the industry participants
and industry associations, while the international
standardization organisations have gotten involved
much later on.
3.1 IPC-175x family of standards
The Association Connecting Electronics Industries has
issued a series of standards known as IPC175x family:
 IPC-1751- Generic Requirements for Declara-
tion Process Management: Provides the princi-
ples and details for declarations necessary be-
tween members of a supply chain relationship
[3].
 IPC-1752- Materials Declaration Management:
Establishes a standard reporting format for ma-
terial declaration data exchange between supply
chain participants and supports reporting of bulk
materials, components, printed circuit boards
(PCBs), sub-assemblies and products [4].
 IPC-1756- Manufacturing Process Data Man-
agement: Establishes defined fields for declara-
tion of manufacturing data as a support for elec-
tronic tools [5].
 IPC-1758- Declaration Requirements for Ship-
ping, Packing and Packaging Materials: De-
scribes essential information exchange content
with respect to packing, supplemented by regu-
lation references for materials, marking, recy-
cling information and recycled content [6].
Further relevant standards are currently in develop-
ment:
 IPC-1753: Laminate Structure Declaration
Management
 IPC-1754: Printed Board Declaration Manage-
ment
 IPC-1755: Electronic Assembly Declaration
Management
The main approach of this standards family is to in-
troduce the process of data managing, the form of data
exchange and the content of exchanged data and tried
to consider the most important requirements of the
wold legal requirements (see chapter 2).
Even though the IPC standards have reached relative
widely recognized status and introduced a pointer out
of the electronic industry but they don’t have the sta-
tus of international standard.
3.2 IEC-62474
The first international standard for material declara-
tion in the electrotechnical industry is called IEC
62474 Edition 1.0 (2012-03), published by the Inter-
national Electrotechnical Commission.
This standard is aimed at harmonizing requirements
for the exchange of material composition data across
the supply chain. To this end, it provides reporting
substances and materials and defines protocols.
There is a database which contains the substances,
substance groups, material classes and typical applica-

3. tions examples, reporting thresholds and basic criteria
for inclusion. There are three basic inclusion criteria
are:
 “Currently regulated”: Substance group or sub-
stance with a “mandatory reporting require-
ment”, included within an existing national law
or regulation in an IEC Member country [1]
(prohibited, restricted or, to declare the usage in
electrotechnical products by a specific date)
 “For information only”: Substance group or
substance with a “mandatory reporting require-
ment”, included within an existing national law
or regulation in an IEC Member country [1]
(prohibited, restricted or, to declare the usage in
electrotechnical products without a specific
date)
 “For assessment”: Substance group or substance
with a “optional reporting requirement”, cur-
rently not regulated in an existing national law
or regulations in an IEC Member country [1]
but there is a recognized industry-wide common
market requirement for reporting this substance
group or substance in electrotechnical products.
Figure 1 displays the base mandatory requirements for
a material declaration according to IEC 62474. They
include the reporting of any substances and substance
groups (listed in the database) included in the final
product that is provided to customers. Furthermore,
every homogeneous material that contains a declarable
substance above the given threshold needs also to be
declared [2].
Figure 1: IEC42474 base requirements for materi-
al declaration [2]
The additional declaration requirements are summa-
rised in figure 2. Reporting of additional substances
(not contained in the database of declarable substanc-
es), substance groups, product (sub)parts and material
classes is optional.
IEC 62474 defines a XML format, developers’ table
and schema for electronic data exchange. Its purpose
is to help in-house and commercial software develop-
ers have a standardized method of data exchange [2].
Figure 2: IEC42474 additional requirements for
material declaration [2]
4 Concept of a data management
and compliance system
In the electronics industry, there are a number of par-
allel systems for the communication, exchanging of
material data and compliance checks in the supply
chain. This is to be expected due to the very high
number of suppliers in this field. So far, a widely ac-
cepted joint system could not be achieved; hence it is
not realistic to expect an industry-wide homogeneous
solution. Most production companies prefer to devel-
op their own systems or to join different systems (see
chapter 2). Therefore, a flexible solution for the ex-
change of information between systems is needed.
The exchange of information shall take place between:
 Commercial software solutions (such as
IMDS and BOMcheck)
 Existing in-house IT environments
 Companies own systems for material declara-
tion
 Various public data systems, such as the Eu-
ropean Chemicals Agency (ECHA) or the
German hazardous materials information sys-
tem (GESTIS).
The software integration tool iPoint Compliance
Agent (iPCA) implements this approach. The system
accesses the existing component, material and sub-
stance data throughout the value chain. Additionally,
for the communication outside of existing systems,
iPCA offers a module for data delivery/import, e.g. the
Supplier Entry Portal (see Figure 3). Figure 3 shows
the core modules of iPCA with an expanded material
and supplier management functionality, including the
ability to connect and communicate with the in-house

4. PDM/PLM system. Connection with a supplier’s in-
ternal systems is possible via a “Supplier Entry Por-
tal” (data communication with supplier). Here, special
interfaces allow for data to be uploaded from the sup-
plier’s own system or through manual data input. Fur-
ther interfaces connect the system with other third par-
ty systems (e.g. the European Chemicals Agency
ECHA, or the German hazardous materials infor-
mation system GESTIS). Additionally, a specialized
functionality, known as agent technology, searches the
available data online which is provided by suppliers.
Figure 3: Integration of systems in iPCA
With iPCA, an open communication between different
systems is implemented. Concurrently, a user admin-
istration with clearly defined rights has been devel-
oped. This ensures high data security, while providing
filtered and task-oriented access to the required data.
In order to effectively secure the intellectual property
of the manufacturers, the iPCA application runs local-
ly on the in-house system. Thus, all product-specific
data (bill of material, specifications, compliance doc-
uments, etc.) are saved and managed exclusively on
the in-house PDM systems.
Figure 4 shows the complete process of conformity
assessment by iPCA. The compliance check of a
product is started by the user (legal or quality manag-
ers) importing the bill of material (BOM) from the in-
house PDM system. The input data will be automati-
cally imported and verified by iPCA. The data check
covers both the correctness of the individual items in
the bill of material (that means questions like com-
pleteness of parts, naming of used units, correctness of
part numbers etc.) and, for all components, a part
number search in the system database. If the compo-
nent is already saved in the system and contains suffi-
cient supplier information, it will be identified and
used for the current and future bill of material anal-
yses and compliance checks. For new, unknown com-
ponents or components with insufficient information,
the appropriate suppliers will be asked to deliver the
relevant information via the Supplier Entry Portal
(SEP). In this way, the system constantly monitors in-
formation already existing in the system or available
on publicly held sources. The input information (mate-
rial declaration, conformity certificate, negative decla-
ration, etc.) will be checked for plausibility and com-
pleteness by the user and for positive results saved in
the system (that means questions like naming of sub-
stances, used units, form and contents of specification
related to a given regulation etc.).
Figure 4: Process flow for checking compliance
with iPCA
In case the data delivered is unusable, another query
will be sent to the supplier. The process of information
collection is automated and the user interaction is re-
duced to a necessary minimum (control of data input).
In the next step, the complete bill of materials is
checked for compliance with pre-defined legal re-
quirements (e.g. RoHS, REACH, ELV etc.). This
means that the legal requirements (e.g. restrictions of
use of specific substances according to REACH) will
be identified, calculated, and compared to the current
limits defined by the regulation. If a substance includ-
ed in a sub-part exceeds the tolerable concentration, a
warning and an adequate report will be created auto-
matically by the system. A team of experts and system
managers makes sure that the legislative changes are
promptly reflected by the application. Each completed
compliance check must be approved by a user before
the information can be saved in the in-house PDM
system. Based upon a check of the bill of materials
and the generated information, the relevant reports
will be automatically created by the system (e.g.
MSDS, reports for public regulators, declaration let-

5. ters etc.). The iPoint Compliance Agent organizes and
manages the entire process of information collection,
integration into in-house systems, analysis and report-
ing.
The most important feature of iPCA is the communi-
cation with other external system and the data integra-
tion into the company-internal PDM/PLM system.
This allows for high data viability on one side and
guarantees the protection and custody of critical intel-
lectual property on the other side.
As well as the compliance check and generating of
COC’s (Certificates of Conformity), the information
collected in the system gives a good basis for improve
sustainability strategies in the development of a prod-
uct. For example, the material specification delivers
appropriate basic information for a Life Cycle As-
sessment of products, and can be later used for the op-
timization of the environmental performance of prod-
ucts and production processes.
5 Conclusion
An effective material declaration system should not
only operate with a company’s own supply chain and
be well integrated into internal data management
structures, but should also have the ability to com-
municate with other external systems in a global envi-
ronment. This kind of communication is only possible
when adequate data exchange standards are defined,
promoted, implemented and adhered to.
6 Literature
[1] List of IEC members, 2012 [Online] Available:
www.iec.ch
[2] IEC 62474 Ed. 1.0, “Material declaration for
products of and for the electrotechnical indus-
try”, Standard developed by International Elec-
trotechnical Commission, 2012-03.
[3] IPC-1751 Version 2.0, “Generic Requirements
for Declaration Process Management”, Standard
developed by Association Connecting Electron-
ics Industries, 2010.
[4] IPC-1752 Version 2.0, “Materials Declaration
Management”; Standard developed by Associa-
tion Connecting Electronics Industries, 2010
[5] IPC-1756 Version 2.0, “Manufacturing Process
Data Management”, Standard developed by As-
sociation Connecting Electronics Industries,
2010.
[6] IPC-1758, “Declaration Requirements for Ship-
ping, Pack and Packing Materials”, Standard de-
veloped by Association Connecting Electronics
Industries, Pre-publication 2012.