Material Data Management

A practical solution for a materials compliance system in small and medium-sized enterprises (SMEs) must be efficient without overburdening limited staff resources. The focus should be on a bill of materials (BOM)-based approach that integrates data collection directly into the development process.

Avoid redundant filing systems that you have to maintain in parallel. A structured materials inventory also serves as a ‘single source of truth’.

An SME does not need a complex system designed for large corporations. An SME-oriented MCS should be based on the following pillars:

Prevention

Classify your suppliers and purchased parts into risk categories. High-risk parts (e.g. electronics, plastics containing plasticisers) should be subject to targeted testing, whilst simple self-declarations are sufficient for low-risk parts (e.g. uncoated stainless steel).

Maintain control

• Continuously screen bills of materials against current substance regulations and lists of banned substances (e.g. POP Regulation, REACH SVHC or RoHS)
• Regular comparison of bills of materials with current regulations (legislative monitoring)

Act in good time

Be proactive. Establish processes in advance for cases where substances are subject to stricter regulation or banned (e.g. early search for alternatives). 

Material inventory

A separate Excel spreadsheet can quickly become a digital ‘data graveyard’. Integrate the material inventory into the appropriate system.

System integration and connection

Link material data directly to the item number in your material data or product information management (PIM) system.

Digital Product Passport

A well-managed material compliance system is the most important data source for the future Digital Product Passport (DPP). If your data is already structured and machine-readable today, this will significantly reduce the effort required to comply with the upcoming EU regulation.

• In product development and design (R&D)
  E.g. creating bills of materials and conducting product risk assessments
• In procurement and supplier management
  E.g. when obtaining supplier declarations
• In quality assurance and incoming goods inspection
  E.g. during spot checks
• In product management and sales
  E.g. customer enquiries regarding REACH and RoHS
• In the legal department and risk management
  E.g.: REACH Candidate List
• At the end of a product’s life cycle (recycling and disposal)
  E.g.: SCIP database

REACH and RoHS are two key EU directives designed to ensure that products are safe for people and the environment.

Meaning of REACH: Registration, Evaluation, Authorisation and Restriction of Chemicals

Meaning of RoHS: Restriction of Hazardous Substances

POPs and PFAS are two groups of hazardous, man-made industrial chemicals. Both are extremely persistent and harmful to the environment and human health. Many PFAS also belong to the group of POPs, as they share the same extremely persistent and harmful properties.

POPs (Persistent Organic Pollutants)

POP stands for Persistent Organic Pollutants. They hardly break down in nature and remain in the environment for decades.

PFAS (Per- and Polyfluoroalkyl Substances)

PFAS describes a vast group of several thousand synthetic industrial chemicals, which are referred to as ‘forever chemicals’.  They are water-, grease- and dirt-repellent, as well as extremely heat- and chemical-resistant.

TSCA and PROP 65 are two key US laws designed to protect people and the environment from hazardous chemicals. They apply to manufacturers, importers and distributors (often based in Europe as well).

TSCA (Toxic Substances Control Act)

The TSCA is a US federal law on chemical safety, administered by the Environmental Protection Agency (EPA). It regulates the manufacture, import, use and disposal of chemical substances.

PROP 65 (California Proposition 65)

‘Proposition 65’ is a Californian consumer protection law, the Safe Drinking Water and Toxic Enforcement Act. If a product exceeds the specified limit values, it must be clearly and unambiguously labelled before purchase.

IMDS and ELV are two closely related terms from the automotive industry that serve to protect the environment and public health, as well as to facilitate the recycling of vehicles. The two systems are directly interlinked. IMDS is an online material data system used by the automotive industry to demonstrate compliance with ELV requirements.

IMDS (International Material Data System)

IMDS is a global, internet-based database used to archive, exchange and manage materials.

ELV (End-of-Life Vehicles Directive)

The EU End-of-Life Vehicles Directive (Directive 2000/53/EC) establishes environmental requirements for the disposal and recycling of end-of-life vehicles.

Conflict minerals are raw materials that are mined and traded in crisis-hit regions and are used to finance armed conflicts, human rights abuses or forced labour.

In the EU, these minerals are regulated by the EU Regulation laying down supply chain due diligence obligations for Union importers of tin, tantalum, tungsten, their ores and gold originating from conflict-affected and high-risk areas.

The Dodd-Frank Act imposes reporting and disclosure obligations on US-listed companies regarding the use of conflict minerals. However, as the Act also imposes requirements on these companies’ supply chains, it may indirectly affect foreign companies if they are suppliers or sub-suppliers to the US companies in question.