Material declaration for products of and for the electrotechnical industry - Part 1: Guidance for the implementation of IEC 62474

IEC 62474-1:2015(E) specifies the procedure, content, and form relating to material declarations for products of companies operating in and supplying the electrotechnical industry. It illustrates the flexibility and functionality of IEC 62474 using examples, supports organizations that create software to exchange substance and material data, supports users that submit and receive material declarations and is designed to support consistent implementation of IEC 62474. Clause 3 summarizes industry needs for material information and business benefits related to IEC 62474. Clause 4 provides case studies that describe the functionality of IEC 62474. Clause 5 provides detailed representations and XML files for the material declaration case studies included in Clause 4.

General Information

Status
Replaced
Publication Date
10-Dec-2015
Drafting Committee
WG 1 - TC 111/WG 1
Current Stage
DELPUB - Deleted Publication
Start Date
16-Nov-2022
Completion Date
26-Oct-2025

Relations

Effective Date
05-Sep-2023
Technical report

IEC TR 62474-1:2015 - Material declaration for products of and for the electrotechnical industry - Part 1: Guidance for the implementation of IEC 62474

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72 pages
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Technical report

IEC TR 62474-1:2015 - Material declaration for products of and for the electrotechnical industry - Part 1: Guidance for the implementation of IEC 62474 Released:12/11/2015 Isbn:9782832230459

English language
72 pages
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Frequently Asked Questions

IEC TR 62474-1:2015 is a technical report published by the International Electrotechnical Commission (IEC). Its full title is "Material declaration for products of and for the electrotechnical industry - Part 1: Guidance for the implementation of IEC 62474". This standard covers: IEC 62474-1:2015(E) specifies the procedure, content, and form relating to material declarations for products of companies operating in and supplying the electrotechnical industry. It illustrates the flexibility and functionality of IEC 62474 using examples, supports organizations that create software to exchange substance and material data, supports users that submit and receive material declarations and is designed to support consistent implementation of IEC 62474. Clause 3 summarizes industry needs for material information and business benefits related to IEC 62474. Clause 4 provides case studies that describe the functionality of IEC 62474. Clause 5 provides detailed representations and XML files for the material declaration case studies included in Clause 4.

IEC 62474-1:2015(E) specifies the procedure, content, and form relating to material declarations for products of companies operating in and supplying the electrotechnical industry. It illustrates the flexibility and functionality of IEC 62474 using examples, supports organizations that create software to exchange substance and material data, supports users that submit and receive material declarations and is designed to support consistent implementation of IEC 62474. Clause 3 summarizes industry needs for material information and business benefits related to IEC 62474. Clause 4 provides case studies that describe the functionality of IEC 62474. Clause 5 provides detailed representations and XML files for the material declaration case studies included in Clause 4.

IEC TR 62474-1:2015 is classified under the following ICS (International Classification for Standards) categories: 01.110 - Technical product documentation; 13.020.01 - Environment and environmental protection in general; 29.060.10 - Wires; 29.100.01 - Components for electrical equipment in general. The ICS classification helps identify the subject area and facilitates finding related standards.

IEC TR 62474-1:2015 has the following relationships with other standards: It is inter standard links to IEC TS 62474-1:2022. Understanding these relationships helps ensure you are using the most current and applicable version of the standard.

IEC TR 62474-1:2015 is available in PDF format for immediate download after purchase. The document can be added to your cart and obtained through the secure checkout process. Digital delivery ensures instant access to the complete standard document.

Standards Content (Sample)


IEC TR 62474-1 ®
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TECHNICAL
REPORT
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Material declaration for products of and for the electrotechnical industry –
Part 1: Guidance for the implementation of IEC 62474
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IEC TR 62474-1 ®
Edition 1.0 2015-12
TECHNICAL
REPORT
colour
inside
Material declaration for products of and for the electrotechnical industry –

Part 1: Guidance for the implementation of IEC 62474

INTERNATIONAL
ELECTROTECHNICAL
COMMISSION
ICS 01.110; 13.020; 29.100; 31.020 ISBN 978-2-8322-3045-9

– 2 – IEC TR 62474-1:2015 © IEC 2015
CONTENTS
FOREWORD . 5
1 Scope . 7
2 Normative references . 7
3 Industry needs and business benefits . 7
3.1 Industry needs . 7
3.2 Business benefits . 8
4 Material declaration approach and flexibility of IEC 62474 . 9
4.1 Material declaration approach . 9
4.1.1 General . 9
4.1.2 Guidance on use of conditional fields in the developers table . 10
4.1.3 Guidance on use of mass and mass percent fields . 11
4.1.4 Calculating mass percent. 11
4.1.5 Interpretation of reporting threshold for declarable substances and
declarable substance groups . 12
4.1.6 Guidance on declaring a substance that belongs to two different
substance groups . 12
4.2 Flexibility of IEC 62474 . 13
4.2.1 Overview of material declaration features . 13
4.2.2 Flexibility of declaring substances and substance groups at different
levels within the declaration . 13
4.2.3 Declarable substances in a material declaration . 13
4.2.4 Additional guidance on declaration of material classes . 14
4.2.5 Absence declaration . 15
4.2.6 Material names . 15
4.2.7 Use of the query list features . 16
4.2.8 Declaring exemptions . 16
4.2.9 Using the reportingThreshold, aboveThresholdLevel and the
reportableApplication fields. 18
4.2.10 How to declare a product that does not have a fixed mass . 19
5 Material declaration examples . 19
5.1 General . 19
5.2 Example 1 – An electronic component . 19
5.2.1 General . 19
5.2.2 Material declaration reporting “base data requirements” . 21
5.2.3 Material declaration reporting base data requirements with optional
additional data fields to provide information on material and exemption
information for RoHS substances . 22
5.2.4 Material declaration reporting additional information for 100 percent of
the product composition . 25
5.2.5 Material declaration reporting additional information with one
undeclared substance . 31
5.3 Example 2 – A product family of capacitors . 38
5.3.1 General . 38
5.3.2 Reporting material declaration according to“base data requirements” . 38
5.3.3 Material declaration reporting additional information for 100 percent of
the product composition . 41
5.4 Example 3 – An assembly consisting of a circuit board and a battery . 44
5.4.1 General . 44

5.4.2 Material declaration reporting “base data requirements” . 45
5.4.3 Material declaration reporting “Additional requirements” for 100 percent
of the product composition . 47
5.5 Example 4 – A product containing a substance which falls under both
REACH Annex XVII and REACH candidate list of substances of very high
concern (SVHC) . 53
5.5.1 General . 53
5.5.2 Material declaration reporting based on “base data requirements” with
optional additional data fields . 55
5.6 Example 5 – Material declaration reporting additional information declaring
based on query lists and for product parts. 57
5.6.1 General . 57
5.7 Example 6 – Thresholds referring to metals . 63
5.7.1 General . 63
5.7.2 Material declaration reporting “base data requirements” . 64
5.7.3 Material declaration reporting additional information declaring reference
substances for a declarable substance group . 66
Annex A (informative) Guidance to declare substances of unknown or variable
composition, complex reaction products and biological materials (UVCBs) . 68
Bibliography . 72

Figure 1 – Conceptual diagram for base requirements . 9
Figure 2 – Conceptual diagram for additional requirements . 10
Figure 3 – Base data requirements – XML . 22
Figure 4 – Additional information – XML for 100 percent product information . 30
Figure 5 – Additional information – XML with one undeclared substance . 37
Figure 6 – Base data requirements – XML . 40
Figure 7 – Additional information – XML for 100 percent of the product composition . 43
Figure 8 – Base data requirements – XML . 46
Figure 9 – Additional information – XML for 100 percent of the assembly composition . 52
Figure 10 – Base data requirements with optional additional data fields – XML . 56
Figure 11 – Base data requirements with optional additional data fields – XML . 62
Figure 12 – Base data requirements – XML . 65
Figure 13 – Base data requirements with optional additional data fields – XML . 67

Table 1 – Conversion table from ppm to mass percent . 11
Table 2 – Use of query list . 16
Table 3 – IPC 1752A exemption specification example . 17
Table 4 – JAMP application list for RoHS exemption list example . 18
Table 5 – JAMP exemption specification example . 18
Table 6 – Base data requirements – Business information . 21
Table 7 – Base data requirements – Product information . 21
Table 8 – Base data requirements – Substance group/substance information . 21
Table 9 – Additional requirements – Material information and exemptions. 23
Table 10 – Additional information – Material class information for 100 percent of the
product composition . 25

– 4 – IEC TR 62474-1:2015 © IEC 2015
Table 11 – Additional information – Product material/substance group/substance
information for 100 percent of the product composition . 26
Table 12 – Additional information – Declaration of material class information with one
undeclared substance and statements about RoHS substance levels . 31
Table 13 – Additional information – Product material/substance group/substance
information with one undeclared substance . 32
Table 14 – Base data requirements – Product information . 39
Table 15 – Additional information – Material class information for 100 percent of the
product composition . 41
Table 16 – Additional information – Declaration of 100 percent of product composition . 41
Table 17 – Base data requirements – Product information . 45
Table 18 – Base data requirements – Product part information . 45
Table 19 – Base data requirements – Product part and substance group information . 45
Table 20 – Additional information – Product part information . 47
Table 21 – Additional information – Material class information for 100 percent of
assembly composition . 47
Table 22 – Additional information – Product part/material/substance group/ substance
information for 100 percent of assembly composition. . 48
Table 23 – Base data requirements – Product information . 55
Table 24 – Base data requirements with optional additional data fields – Substance
group/substance information . 55
Table 25 – Base data requirements – Business information . 57
Table 26 – Base data requirements – Product information . 57
Table 27 – Base data requirements – Substance group/substance information with
optional additional data fields . 58
Table 28 – Additional information – Query list . 59
Table 29 – Additional information – Product parts . 60
Table 30 – Base data requirements – Business information . 64
Table 31 – Base data requirements – Product information . 64
Table 32 – Base data requirements – Substance group/substance information . 64
Table 33 – Additional information – Product material/substance group/substance
information. 66
Table A.1 – Example for simple glass declaration by the JEITA method . 69
Table A.2 – Example for glass prepared with B2O3 by the JEITA method . 69
Table A.3 – Example for glass prepared with PbO by the JEITA method . 69
Table A.4 – Example for simple ceramic by the JEITA method . 70
Table A.5 – Example for ceramic containing PZT by the JEITA method . 70
Table A.6 – Example for simple glass by the IMDS method . 70
Table A. 7 – Example for specific glass by the IMDS method . 71
Table A.8 – Example for glass containing lead by the IMDS method . 71

INTERNATIONAL ELECTROTECHNICAL COMMISSION
____________
MATERIAL DECLARATION FOR PRODUCTS OF AND FOR THE
ELECTROTECHNICAL INDUSTRY –
Part 1: Guidance for the implementation of IEC 62474

FOREWORD
1) The International Electrotechnical Commission (IEC) is a worldwide organization for standardization comprising
all national electrotechnical committees (IEC National Committees). The object of IEC is to promote
international co-operation on all questions concerning standardization in the electrical and electronic fields. To
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8) Attention is drawn to the Normative references cited in this publication. Use of the referenced publications is
indispensable for the correct application of this publication.
9) Attention is drawn to the possibility that some of the elements of this IEC Publication may be the subject of
patent rights. IEC shall not be held responsible for identifying any or all such patent rights.
The main task of IEC technical committees is to prepare International Standards. However, a
technical committee may propose the publication of a Technical Report when it has collected
data of a different kind from that which is normally published as an International Standard, for
example "state of the art".
IEC TR 62474-1, which is a Technical Report, has been prepared by IEC technical committee
111: Environmental standardization for electrical and electronic products and systems.
The text of this Technical Report is based on the following documents:
Enquiry draft Report on voting
111/359/DTR 111/369/RVC
Full information on the voting for the approval of this Technical Report can be found in the
report on voting indicated in the above table.

– 6 – IEC TR 62474-1:2015 © IEC 2015
This publication has been drafted in accordance with the ISO/IEC Directives, Part 2.
A list of all parts in the IEC 62474 series, published under the general title Material
declaration for products of and for the electrotechnical industry, can be found on the IEC
website.
The committee has decided that the contents of this publication will remain unchanged until
the stability date indicated on the IEC website under "http://webstore.iec.ch" in the data
related to the specific publication. At this date, the publication will be
• reconfirmed,
• withdrawn,
• replaced by a revised edition, or
• amended.
A bilingual version of this publication may be issued at a later date.

IMPORTANT – The 'colour inside' logo on the cover page of this publication indicates
that it contains colours which are considered to be useful for the correct
understanding of its contents. Users should therefore print this document using a
colour printer.
MATERIAL DECLARATION FOR PRODUCTS OF AND FOR THE
ELECTROTECHNICAL INDUSTRY –
Part 1: Guidance for the implementation of IEC 62474

1 Scope
This part of IEC 62474, which is a Technical Report, is a guidance document to help
organizations that create tools for material data exchange and organizations that submit and
receive material declarations to properly implement IEC 62474.
IEC 62474 specifies the procedure, content, and form relating to material declarations for
products of companies operating in and supplying the electrotechnical industry.
This Technical Report:
• illustrates the flexibility and functionality of IEC 62474 using examples,
• supports organizations that create software to exchange substance and material data,
• supports users that submit and receive material declarations, and
• is designed to support consistent implementation of IEC 62474.
Clause 3 summarizes industry needs for material information and business benefits related to
IEC 62474.
Clause 4 provides case studies that describe the functionality of IEC 62474.
Clause 5 provides detailed representations and XML files for the material declaration case
studies included in Clause 4.
2 Normative references
The following documents, in whole or in part, are normatively referenced in this document and
are indispensable for its application. For dated references, only the edition cited applies. For
undated references, the latest edition of the referenced document (including any
amendments) applies.
IEC 62474:2012, Material declaration for products of and for the electrotechnical industry
3 Industry needs and business benefits
3.1 Industry needs
Today, there are ever increasing legal regulations in many countries from around the world
and supply chain requirements that may restrict the use of substances in products, require
reporting and/or require notifications of substance uses.
To determine restricted substance compliance status, electrotechnical product manufacturers
need information about restricted substances contained in supplied products that become part
of the manufacturer’s products.

– 8 – IEC TR 62474-1:2015 © IEC 2015
Electrotechnical product manufacturers also need data about materials used in products as
one of the inputs in an environmentally conscious design process to improve environmental
performance of products throughout their product life cycle.
Also, to make material declaration data readily available, the supply chain (including
organizations providing products into the electrotechnical industry) needs a standardized
method to exchange the data.
3.2 Business benefits
IEC 62474 was developed to standardize the multiple existing approaches into a single global
approach for the electrotechnical industry.
Material declarations according to IEC 62474 provide all data needed to make a restricted
substance compliance assessment. These material declarations according to IEC 62474 can
be used to obtain the data needed to be included in the technical documentation file required
to place products on the market in different regions. Examples are:
• The EU Restriction of Hazardous Substances (RoHS) Directive
• The China Administrative Measures on the Control Pollution Caused by Electronic
Information Products (known as “China RoHS”).
IEC 62474 specifies the use of a dedicated database that lists substances and substance
groups that require declaration. This provides certainty to suppliers regarding what data they
need to provide, regardless of the customer. The IEC database also includes material classes
that may be used as an input to environmentally conscious design, and a developers table
and schema that specifies data exchange requirements. The IEC 62474 database is
maintained and regularly updated by global experts to meet changing legislation and broad
customer requirements. The database can be found at: http://std.iec.ch/iec62474.
Implementing IEC 62474 improves data quality and reduces cost, because it offers a
standardized method to support material declaration data throughout the supply chain.
The data required about products, product parts and materials can be extensive, and the
electrotechnical industry benefits from a standardized way to exchange this data as well as
provides a defined list of declarable substances through the IEC 62474 database. This
reduces the risk of data entry errors as well as unnecessary reporting of substances that do
not apply to electrical and electronic products.
The standard is flexible, identifying base requirements, but also allowing all levels of
additional reporting under defined rules, so that the data is properly exchanged through the
supply chain. The data exchange format specification allows the supply chain to use a single
format to exchange their data rather than replying to each customer’s custom format. The
capability to send and receive data in the IEC 62474 format allows suppliers to provide data
and customers to request data. How the data is stored remains independent of how it is
exchanged.
IEC standards are recognized by the World Trade Organization (WTO), which means that
IEC 62474 can be referenced as the global standard for material declarations applicable to
the electrotechnical industry.
Broad implementation by electrotechnical industry organizations will result in:
• material declaration data being available as a condition to sell to the eletrotechnical
industry,
• availability of material declaration data that is not dependent on an organization’s size
or purchase volume,
• improvement of data quality, reduction of compliance costs and elimination of
inefficiencies, and
• faster assessments of products/materials under review.
4 Material declaration approach and flexibility of IEC 62474
4.1 Material declaration approach
4.1.1 General
Subclause 4.1.1 builds on the content given in IEC 62474:2012, 4.1 (for example, by including
the conceptual diagrams for base requirements and additional requirements), and addresses
the following topics:
• base requirements;
• additional requirements;
• conditional requirements.
IEC 62474:2012, Clause 4 is organized in the order of the conceptual diagrams (see Figure 1
and Figure 2 below from IEC 62474) for ease of understanding. Mandatory information is
shown with solid boxes and arrows. These represent the products, substance groups or
substances with a mandatory reporting requirement in the IEC 62474 database.
Product parts, material classes, materials, and substance groups or substances without a
mandatory reporting requirement in the IEC 62474 database are optional and represented
with dotted boxes and arrows. Substance groups and substances not listed in the IEC 62474
database are also optional for declaring. Further mandatory reporting requirements apply
without being displayed in the diagrams (e.g. mass or mass percent). When there is a
substance group with a mandatory reporting requirement, one can declare only the substance
group if there are no underlying declarable substances with a mandatory reporting
requirement at or above the reportable threshold as specified in the IEC 62474 database.
Substance
with mandatory reporting
requirement in IEC DB 62474
Product And/or
Substance group Substance
with mandatory reporting with mandatory reporting
requirement in IEC DB 62474 requirement in IEC DB 62474
IEC
Figure 1 – Conceptual diagram for base requirements

– 10 – IEC TR 62474-1:2015 © IEC 2015
Substance
Substance group Substance
with mandatory reporting
requirement in IEC DB 62474
Product
Product Material
And/or
part
Requirement in IEC DB 62474
Substance
Material class
Substance group
Substance
with mandatory reporting
with mandatory reporting
requirement in IEC DB 62474
requirement in IEC DB 62474
IEC
Note The arrow around the product part indicates that any product part could be broken down into further product
parts and thus it indicates that the product assembly is not just limited to two levels (product – product part) as
displayed in this conceptual diagram.
Figure 2 – Conceptual diagram for additional requirements
A user may only state that it is in conformance with IEC 62474 if it has:
• included all declarable substances and substance groups with a mandatory reporting
requirement that are present in the product at or above the reporting threshold as per
the IEC 62474 database, and
• followed the IEC 62474 XML data exchange (schema and developers table).
If a user is reporting more than the base data requirements, then conformance to IEC 62474
also includes:
• meeting all of the "additional requirements" associated with any optional information
that is reported, and
• meeting all the detailed data requirements specified in the IEC 62474 XML schema
and developers table.
IEC 62474 specifies that only substances that remain in the product may be declared in the
material declaration file. IEC 62474 also requires that manufacturing chemicals that react,
form other chemicals or otherwise do not remain in the product are not to be included. For
example, for a resin and a hardener that are used to form epoxy in a product, the final epoxy
substance should be declared if it is a declarable substance or as a voluntary declaration. The
individual resin and hardener chemical could be declared only if a residual amount of these
chemicals remained in the product.
The recursive nature of product parts (shown in Figure 2 above with the arrow back to product
parts), allows the users flexibility to report multiple levels within a product’s “Bill of Materials”
(BOM) such that users are not just limited to only one part level under the product. For
example, one can declare a personal computer (product) with a mother board (product part 1)
with a coin cell battery (product part of product part 1). This flexibility enables all users within
the electronic industry supply chain to be able to effectively utilize the IEC 62474 XML
schema.
4.1.2 Guidance on use of conditional fields in the developers table
The IEC 62474 developers table includes a column (Obligation column) that indicates whether
a specific data field (element or attribute) is mandatory or optional. Some data fields are listed
as conditional. These fields are mandatory under certain material declaration conditions,
optional under other conditions. A conditional obligation may also cause an element or
attribute to become not applicable under certain conditions and therefore it may not be used
in that particular instance.
For example, the “identifier” attribute within the ProductID class is listed with a conditional
obligation. If the ProductID is used to identify the product at the top of the material declaration
hierarchy, then the identifier information is mandatory and must be provided by the user in the
material declaration. However, if the ProductID is used in declaring a product part that is
lower in the declaration hierarchy, this identifier information is optional.
There are a few other data elements and attributes that are also listed with a conditional
obligation. The Mass, MassPercent, and MatMassPercent elements have particularly complex
conditional provisions that must be carefully reviewed to ensure correct implementation.
4.1.3 Guidance on use of mass and mass percent fields
IEC 62474 specifies that a declaration is required to report either mass or mass percent, but
not both. This is important for data quality purposes as only one data field is variable and the
second data field is a calculated value.
If both the mass percent and the mass are declared, but due to errors the calculation does not
correspond to the reported mass, then the receiver of the material declaration will not know
which number is the correct one to use.
A general rule of thumb is to report using mass percent when reporting product families (e.g.
ICs, resistors, capacitors, etc) which contain multiple products in one declaration, but to use
mass when reporting assemblies or finished goods when a single product is declared.
Reporting concentrations (mass percent) for product families provides sufficient data for the
receiver of the declaration to correctly calculate the mass of each product in the family in their
IT software system tools, while streamlining the number of material declarations to be
exchanged between the two companies.
4.1.4 Calculating mass percent
In the material declaration, either mass or mass percent for the substance, substance group,
material or product part can be used.
Many laboratories report concentrations in ppm. One ppm means 1 part in 1 000 000 like
parts, such as grams to gram basis. ppm is converted to mass percent for such cases by the
formula Mass percent = X ppm / 10 000.
See Table 1 for conversion from ppm to mass percent.
Table 1 – Conversion table from ppm to mass percent
Percent (%) ppm = (mg/kg)
0,000 1 %         1
0,001 %        10
0,01 %       100
0,1 %      1 000
1,0 %     10 000
10,0 %   100 000
100,0 %  1 000 000
With one justified exception, mass percent is always referring to the next higher level in the
product hierarchy that is declared. This means that mass percent will refer to the material,
product part or product. The exception is that if a substance is assigned to a substance group
in the declaration (see IEC 62474:2012, 4.2.3 a), 4.3.4 a) and 4.3.5 a)), the mass percent
refers to material (if declared), product part (if declared) or to the product. The mass percent
of a substance is never calculated based on the mass of the substance group. Declaring a

– 12 – IEC TR 62474-1:2015 © IEC 2015
substance as a mass percent of the substance group can cause errors and therefore it is not
allowed in IEC 62474. This is stated in the relevant requirements included in IEC 62474:2012,
4.2.3 c), 4.3.4 c) and 4.3.5 c).
This deviation from the generic rule ensures that the recipient of a material declaration is able
to interpret the data correctly under any combination of base and optional reporting. This is
necessary to cope with situations where a declarable substance group has a reporting
requirement that is based on materials (e.g. homogeneous material). The situation is further
complicated when only a part of the compound (e.g. the lead in lead/lead compounds) is to be
declared. As some substances within the substance group may be unknown, the information
on percentage of the declared substances within the substance group cannot be
unambiguously correlated to the mandatory material mass percent declaration, and as a
consequence a further transfer of this information would not be of use.
As a consequence, the declaration of mass percent of a substance within a substance group
is not allowed in IEC 62474. To secure that the voluntarily provided declaration of a
substance is useful for any follow-up declarations, its mass or mass percent of the material (if
declared), product part (if declared) or product is needed.
To convert from mass to mass percent, one divides the mass of the substance or substance
group by the mass of the product, product part or material and then converts to percent.
Mass percent = mass of substance/mass of product, part or material × 100 percent.
The only time the MatMassPercent data field is used in the XML file is when the IEC 62474
database has a mandatory reporting threshold at the material level. For all other instances,
either the Mass or the MassPercent data field should be used in the XML file.
4.1.5 Interpretation of reporting threshold for declarable substances and declarable
substance groups
For most of the declarable substance and declarable substance group entries in the
IEC 62474 database, the reporting threshold is based on the mass percent of the product.
This is represented by a reporting threshold that is listed as "0,1 mass percent". The
reference to the mass of the product that is declared is implied in this threshold. However,
there are declarable substances and declarable substance groups that have a reporting
threshold with a different calculation basis. The EU RoHS declarable substance groups are
examples that use the mass of the homogeneous material as the basis for calculation. If the
reporting threshold refers to something other than the product (such as a material or a
product part like a battery), this is indicated in the IEC 62474 database.
4.1.6 Guidance on declaring a substance that belongs to two different substance
groups
A material declaration that conforms to IEC 62474 requires that a declared substance with a
mandatory reporting requirement must be assigned to its respective declarable substance
group with a mandatory reporting requirement, if the declarable substance group is declared.
The requirement “such substances shall be assigned to the substance group”is specified in
IEC 62474:2012, 4.2.3 a) and 4.3.4 a).
In most material declarations this is straightforward. However, since the establishment of
IEC 62474, several corner cases have emerged with a declarable substance fitting into two
declarable substance groups. For example, the REACH SVHC substance “Lead sulfochromate
yellow” creates such a situation. The declarable substance groups “Lead/Lead Compounds”
and “Chromium (VI) Compounds” are both relevant. "Lead/Lead Compounds” and “Chromium
(VI) Compounds” need to be declared if they are present at or above the reporting threshold
for each homogenous material. However, it is not possible in an XML file (by the design of the
XML schema) to assign the same occurrence of “Lead sulfochromate yellow” to both
substance groups simultaneously even if the Lead sulfochromate yellow triggered the

declaration of both declarable substance groups. Reporting this occurrence under both
Lead/Lead Compounds” and “Chromium (VI) Compounds” would incorrectly double the total
amount of Lead sulfochromate yellow and should be avoided, too.
Several possibilities arise for assigning the substance group in such situations. In the case of
Lead sulfochromate yellow, the responder (supplier filling out the material declaration) needs
to select one of the respective declarable substance groups and assign the substance to it.
Regardless of which declarable substance group is selected, the responder still needs to state
the presence of the other declarable substance group if it exceeds the threshold.
4.2 Flexibility of IEC 62474
4.2.1 Overview of material declaration features
Beyond the minimum declaration requirements specified in IEC 62474:2012, 4.2, base data
requirements and detailed data requirements as per the IEC 62474 XML schema, users have
significant flexibility in providing additional information that is useful in material declaration
exchanges up and down the supply chain.
4.2.2 Flexibility of declaring substances and substance groups at different levels
within the declaration
Users have flexibility as to how substances and substance groups are declared within the
hierarchy of the material declaration created in the XML file. For example, a user may
voluntarily declare the material for some substances; whereas other substances (such as EU
REACH SVHCs) may be represented as reporting directly into the product. This flexibility is
illustrated in Example 6 (see 5.7). If there are any restrictions on how a declarable substance
or declarable substance group is to be reported; this information will be provided in the
reporting threshold on the IEC 62474 database.
4.2.3 Declarable substances in a material declaration
4.2.3.1 General
The declarable substances and declarable substance groups in IEC 62474 are central to the
declaration. If they are present in the product, and meet or exceed the reporting threshold for
that particular application, it is required that these substances and substance groups are
identified in the material declaration if they have a mandatory reporting requirement.
Otherwise the declaration does not fulfil the requirements of IEC 62474. There are two
specific situations that are sometimes overlooked and deserve additional discussion in this
guidance document. These are trade secrets and substances with a CAS number that
contains other substances, which are discussed below.
4.2.3.2 Trade secret
Suppliers might have special alloys or compounds that are central for the function and where
the supplier does not want to disclose the exact composition.
For materials that are considered as a “trade secret”, IEC 62474 specifies that any declarable
substances or substance groups contained in such a material need to be declared if they have
a mandatory reporting requirement and are present in the product at or above the reporting
threshold for its associated reportable application.
4.2.3.3 Substances with a CAS-number that contains other su
...


IEC TR 62474-1 ®
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TECHNICAL
REPORT
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Material declaration for products of and for the electrotechnical industry –
Part 1: Guidance for the implementation of IEC 62474

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IEC TR 62474-1 ®
Edition 1.0 2015-12
TECHNICAL
REPORT
colour
inside
Material declaration for products of and for the electrotechnical industry –

Part 1: Guidance for the implementation of IEC 62474

INTERNATIONAL
ELECTROTECHNICAL
COMMISSION
ICS 01.110; 13.020; 29.100; 31.020 ISBN 978-2-8322-3045-9

– 2 – IEC TR 62474-1:2015 © IEC 2015

CONTENTS
FOREWORD . 5

1 Scope . 7

2 Normative references . 7

3 Industry needs and business benefits . 7

3.1 Industry needs . 7

3.2 Business benefits . 8

4 Material declaration approach and flexibility of IEC 62474 . 9

4.1 Material declaration approach . 9
4.1.1 General . 9
4.1.2 Guidance on use of conditional fields in the developers table . 10
4.1.3 Guidance on use of mass and mass percent fields . 11
4.1.4 Calculating mass percent. 11
4.1.5 Interpretation of reporting threshold for declarable substances and
declarable substance groups . 12
4.1.6 Guidance on declaring a substance that belongs to two different
substance groups . 12
4.2 Flexibility of IEC 62474 . 13
4.2.1 Overview of material declaration features . 13
4.2.2 Flexibility of declaring substances and substance groups at different
levels within the declaration . 13
4.2.3 Declarable substances in a material declaration . 13
4.2.4 Additional guidance on declaration of material classes . 14
4.2.5 Absence declaration . 15
4.2.6 Material names . 15
4.2.7 Use of the query list features . 16
4.2.8 Declaring exemptions . 16
4.2.9 Using the reportingThreshold, aboveThresholdLevel and the
reportableApplication fields. 18
4.2.10 How to declare a product that does not have a fixed mass . 19
5 Material declaration examples . 19
5.1 General . 19
5.2 Example 1 – An electronic component . 19
5.2.1 General . 19

5.2.2 Material declaration reporting “base data requirements” . 21
5.2.3 Material declaration reporting base data requirements with optional
additional data fields to provide information on material and exemption
information for RoHS substances . 22
5.2.4 Material declaration reporting additional information for 100 percent of
the product composition . 25
5.2.5 Material declaration reporting additional information with one
undeclared substance . 31
5.3 Example 2 – A product family of capacitors . 38
5.3.1 General . 38
5.3.2 Reporting material declaration according to“base data requirements” . 38
5.3.3 Material declaration reporting additional information for 100 percent of
the product composition . 41
5.4 Example 3 – An assembly consisting of a circuit board and a battery . 44
5.4.1 General . 44

5.4.2 Material declaration reporting “base data requirements” . 45

5.4.3 Material declaration reporting “Additional requirements” for 100 percent

of the product composition . 47

5.5 Example 4 – A product containing a substance which falls under both

REACH Annex XVII and REACH candidate list of substances of very high

concern (SVHC) . 53

5.5.1 General . 53

5.5.2 Material declaration reporting based on “base data requirements” with

optional additional data fields . 55

5.6 Example 5 – Material declaration reporting additional information declaring
based on query lists and for product parts. 57

5.6.1 General . 57
5.7 Example 6 – Thresholds referring to metals . 63
5.7.1 General . 63
5.7.2 Material declaration reporting “base data requirements” . 64
5.7.3 Material declaration reporting additional information declaring reference
substances for a declarable substance group . 66
Annex A (informative) Guidance to declare substances of unknown or variable
composition, complex reaction products and biological materials (UVCBs) . 68
Bibliography . 72

Figure 1 – Conceptual diagram for base requirements . 9
Figure 2 – Conceptual diagram for additional requirements . 10
Figure 3 – Base data requirements – XML . 22
Figure 4 – Additional information – XML for 100 percent product information . 30
Figure 5 – Additional information – XML with one undeclared substance . 37
Figure 6 – Base data requirements – XML . 40
Figure 7 – Additional information – XML for 100 percent of the product composition . 43
Figure 8 – Base data requirements – XML . 46
Figure 9 – Additional information – XML for 100 percent of the assembly composition . 52
Figure 10 – Base data requirements with optional additional data fields – XML . 56
Figure 11 – Base data requirements with optional additional data fields – XML . 62
Figure 12 – Base data requirements – XML . 65
Figure 13 – Base data requirements with optional additional data fields – XML . 67

Table 1 – Conversion table from ppm to mass percent . 11
Table 2 – Use of query list . 16
Table 3 – IPC 1752A exemption specification example . 17
Table 4 – JAMP application list for RoHS exemption list example . 18
Table 5 – JAMP exemption specification example . 18
Table 6 – Base data requirements – Business information . 21
Table 7 – Base data requirements – Product information . 21
Table 8 – Base data requirements – Substance group/substance information . 21
Table 9 – Additional requirements – Material information and exemptions. 23
Table 10 – Additional information – Material class information for 100 percent of the
product composition . 25

– 4 – IEC TR 62474-1:2015 © IEC 2015

Table 11 – Additional information – Product material/substance group/substance

information for 100 percent of the product composition . 26

Table 12 – Additional information – Declaration of material class information with one

undeclared substance and statements about RoHS substance levels . 31

Table 13 – Additional information – Product material/substance group/substance
information with one undeclared substance . 32

Table 14 – Base data requirements – Product information . 39

Table 15 – Additional information – Material class information for 100 percent of the

product composition . 41

Table 16 – Additional information – Declaration of 100 percent of product composition . 41

Table 17 – Base data requirements – Product information . 45
Table 18 – Base data requirements – Product part information . 45
Table 19 – Base data requirements – Product part and substance group information . 45
Table 20 – Additional information – Product part information . 47
Table 21 – Additional information – Material class information for 100 percent of
assembly composition . 47
Table 22 – Additional information – Product part/material/substance group/ substance
information for 100 percent of assembly composition. . 48
Table 23 – Base data requirements – Product information . 55
Table 24 – Base data requirements with optional additional data fields – Substance
group/substance information . 55
Table 25 – Base data requirements – Business information . 57
Table 26 – Base data requirements – Product information . 57
Table 27 – Base data requirements – Substance group/substance information with
optional additional data fields . 58
Table 28 – Additional information – Query list . 59
Table 29 – Additional information – Product parts . 60
Table 30 – Base data requirements – Business information . 64
Table 31 – Base data requirements – Product information . 64
Table 32 – Base data requirements – Substance group/substance information . 64
Table 33 – Additional information – Product material/substance group/substance
information. 66
Table A.1 – Example for simple glass declaration by the JEITA method . 69
Table A.2 – Example for glass prepared with B2O3 by the JEITA method . 69

Table A.3 – Example for glass prepared with PbO by the JEITA method . 69
Table A.4 – Example for simple ceramic by the JEITA method . 70
Table A.5 – Example for ceramic containing PZT by the JEITA method . 70
Table A.6 – Example for simple glass by the IMDS method . 70
Table A. 7 – Example for specific glass by the IMDS method . 71
Table A.8 – Example for glass containing lead by the IMDS method . 71

INTERNATIONAL ELECTROTECHNICAL COMMISSION

____________
MATERIAL DECLARATION FOR PRODUCTS OF AND FOR THE

ELECTROTECHNICAL INDUSTRY –
Part 1: Guidance for the implementation of IEC 62474

FOREWORD
1) The International Electrotechnical Commission (IEC) is a worldwide organization for standardization comprising
all national electrotechnical committees (IEC National Committees). The object of IEC is to promote
international co-operation on all questions concerning standardization in the electrical and electronic fields. To
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2) The formal decisions or agreements of IEC on technical matters express, as nearly as possible, an international
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3) IEC Publications have the form of recommendations for international use and are accepted by IEC National
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4) In order to promote international uniformity, IEC National Committees undertake to apply IEC Publications
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6) All users should ensure that they have the latest edition of this publication.
7) No liability shall attach to IEC or its directors, employees, servants or agents including individual experts and
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8) Attention is drawn to the Normative references cited in this publication. Use of the referenced publications is
indispensable for the correct application of this publication.
9) Attention is drawn to the possibility that some of the elements of this IEC Publication may be the subject of
patent rights. IEC shall not be held responsible for identifying any or all such patent rights.

The main task of IEC technical committees is to prepare International Standards. However, a
technical committee may propose the publication of a Technical Report when it has collected
data of a different kind from that which is normally published as an International Standard, for
example "state of the art".
IEC TR 62474-1, which is a Technical Report, has been prepared by IEC technical committee
111: Environmental standardization for electrical and electronic products and systems.
The text of this Technical Report is based on the following documents:
Enquiry draft Report on voting
111/359/DTR 111/369/RVC
Full information on the voting for the approval of this Technical Report can be found in the
report on voting indicated in the above table.

– 6 – IEC TR 62474-1:2015 © IEC 2015

This publication has been drafted in accordance with the ISO/IEC Directives, Part 2.

A list of all parts in the IEC 62474 series, published under the general title Material

declaration for products of and for the electrotechnical industry, can be found on the IEC

website.
The committee has decided that the contents of this publication will remain unchanged until

the stability date indicated on the IEC website under "http://webstore.iec.ch" in the data

related to the specific publication. At this date, the publication will be

• reconfirmed,
• withdrawn,
• replaced by a revised edition, or
• amended.
A bilingual version of this publication may be issued at a later date.

IMPORTANT – The 'colour inside' logo on the cover page of this publication indicates
that it contains colours which are considered to be useful for the correct
understanding of its contents. Users should therefore print this document using a
colour printer.
MATERIAL DECLARATION FOR PRODUCTS OF AND FOR THE

ELECTROTECHNICAL INDUSTRY –
Part 1: Guidance for the implementation of IEC 62474

1 Scope
This part of IEC 62474, which is a Technical Report, is a guidance document to help
organizations that create tools for material data exchange and organizations that submit and
receive material declarations to properly implement IEC 62474.
IEC 62474 specifies the procedure, content, and form relating to material declarations for
products of companies operating in and supplying the electrotechnical industry.
This Technical Report:
• illustrates the flexibility and functionality of IEC 62474 using examples,
• supports organizations that create software to exchange substance and material data,
• supports users that submit and receive material declarations, and
• is designed to support consistent implementation of IEC 62474.
Clause 3 summarizes industry needs for material information and business benefits related to
IEC 62474.
Clause 4 provides case studies that describe the functionality of IEC 62474.
Clause 5 provides detailed representations and XML files for the material declaration case
studies included in Clause 4.
2 Normative references
The following documents, in whole or in part, are normatively referenced in this document and
are indispensable for its application. For dated references, only the edition cited applies. For
undated references, the latest edition of the referenced document (including any
amendments) applies.
IEC 62474:2012, Material declaration for products of and for the electrotechnical industry
3 Industry needs and business benefits
3.1 Industry needs
Today, there are ever increasing legal regulations in many countries from around the world
and supply chain requirements that may restrict the use of substances in products, require
reporting and/or require notifications of substance uses.
To determine restricted substance compliance status, electrotechnical product manufacturers
need information about restricted substances contained in supplied products that become part
of the manufacturer’s products.

– 8 – IEC TR 62474-1:2015 © IEC 2015

Electrotechnical product manufacturers also need data about materials used in products as

one of the inputs in an environmentally conscious design process to improve environmental

performance of products throughout their product life cycle.

Also, to make material declaration data readily available, the supply chain (including

organizations providing products into the electrotechnical industry) needs a standardized

method to exchange the data.
3.2 Business benefits
IEC 62474 was developed to standardize the multiple existing approaches into a single global
approach for the electrotechnical industry.
Material declarations according to IEC 62474 provide all data needed to make a restricted
substance compliance assessment. These material declarations according to IEC 62474 can
be used to obtain the data needed to be included in the technical documentation file required
to place products on the market in different regions. Examples are:
• The EU Restriction of Hazardous Substances (RoHS) Directive
• The China Administrative Measures on the Control Pollution Caused by Electronic
Information Products (known as “China RoHS”).
IEC 62474 specifies the use of a dedicated database that lists substances and substance
groups that require declaration. This provides certainty to suppliers regarding what data they
need to provide, regardless of the customer. The IEC database also includes material classes
that may be used as an input to environmentally conscious design, and a developers table
and schema that specifies data exchange requirements. The IEC 62474 database is
maintained and regularly updated by global experts to meet changing legislation and broad
customer requirements. The database can be found at: http://std.iec.ch/iec62474.
Implementing IEC 62474 improves data quality and reduces cost, because it offers a
standardized method to support material declaration data throughout the supply chain.
The data required about products, product parts and materials can be extensive, and the
electrotechnical industry benefits from a standardized way to exchange this data as well as
provides a defined list of declarable substances through the IEC 62474 database. This
reduces the risk of data entry errors as well as unnecessary reporting of substances that do
not apply to electrical and electronic products.
The standard is flexible, identifying base requirements, but also allowing all levels of
additional reporting under defined rules, so that the data is properly exchanged through the
supply chain. The data exchange format specification allows the supply chain to use a single

format to exchange their data rather than replying to each customer’s custom format. The
capability to send and receive data in the IEC 62474 format allows suppliers to provide data
and customers to request data. How the data is stored remains independent of how it is
exchanged.
IEC standards are recognized by the World Trade Organization (WTO), which means that
IEC 62474 can be referenced as the global standard for material declarations applicable to
the electrotechnical industry.
Broad implementation by electrotechnical industry organizations will result in:
• material declaration data being available as a condition to sell to the eletrotechnical
industry,
• availability of material declaration data that is not dependent on an organization’s size
or purchase volume,
• improvement of data quality, reduction of compliance costs and elimination of

inefficiencies, and
• faster assessments of products/materials under review.

4 Material declaration approach and flexibility of IEC 62474

4.1 Material declaration approach

4.1.1 General
Subclause 4.1.1 builds on the content given in IEC 62474:2012, 4.1 (for example, by including

the conceptual diagrams for base requirements and additional requirements), and addresses
the following topics:
• base requirements;
• additional requirements;
• conditional requirements.
IEC 62474:2012, Clause 4 is organized in the order of the conceptual diagrams (see Figure 1
and Figure 2 below from IEC 62474) for ease of understanding. Mandatory information is
shown with solid boxes and arrows. These represent the products, substance groups or
substances with a mandatory reporting requirement in the IEC 62474 database.
Product parts, material classes, materials, and substance groups or substances without a
mandatory reporting requirement in the IEC 62474 database are optional and represented
with dotted boxes and arrows. Substance groups and substances not listed in the IEC 62474
database are also optional for declaring. Further mandatory reporting requirements apply
without being displayed in the diagrams (e.g. mass or mass percent). When there is a
substance group with a mandatory reporting requirement, one can declare only the substance
group if there are no underlying declarable substances with a mandatory reporting
requirement at or above the reportable threshold as specified in the IEC 62474 database.
Substance
with mandatory reporting
requirement in IEC DB 62474
Product And/or
Substance group Substance
with mandatory reporting with mandatory reporting
requirement in IEC DB 62474 requirement in IEC DB 62474

IEC
Figure 1 – Conceptual diagram for base requirements

– 10 – IEC TR 62474-1:2015 © IEC 2015

Substance
Substance group Substance
with mandatory reporting
requirement in IEC DB 62474
Product
Product Material
And/or
part
Requirement in IEC DB 62474
Substance
Material class
Substance group
Substance
with mandatory reporting
with mandatory reporting
requirement in IEC DB 62474
requirement in IEC DB 62474
IEC
Note The arrow around the product part indicates that any product part could be broken down into further product
parts and thus it indicates that the product assembly is not just limited to two levels (product – product part) as
displayed in this conceptual diagram.
Figure 2 – Conceptual diagram for additional requirements
A user may only state that it is in conformance with IEC 62474 if it has:
• included all declarable substances and substance groups with a mandatory reporting
requirement that are present in the product at or above the reporting threshold as per
the IEC 62474 database, and
• followed the IEC 62474 XML data exchange (schema and developers table).
If a user is reporting more than the base data requirements, then conformance to IEC 62474
also includes:
• meeting all of the "additional requirements" associated with any optional information
that is reported, and
• meeting all the detailed data requirements specified in the IEC 62474 XML schema
and developers table.
IEC 62474 specifies that only substances that remain in the product may be declared in the
material declaration file. IEC 62474 also requires that manufacturing chemicals that react,
form other chemicals or otherwise do not remain in the product are not to be included. For
example, for a resin and a hardener that are used to form epoxy in a product, the final epoxy
substance should be declared if it is a declarable substance or as a voluntary declaration. The
individual resin and hardener chemical could be declared only if a residual amount of these
chemicals remained in the product.
The recursive nature of product parts (shown in Figure 2 above with the arrow back to product

parts), allows the users flexibility to report multiple levels within a product’s “Bill of Materials”
(BOM) such that users are not just limited to only one part level under the product. For
example, one can declare a personal computer (product) with a mother board (product part 1)
with a coin cell battery (product part of product part 1). This flexibility enables all users within
the electronic industry supply chain to be able to effectively utilize the IEC 62474 XML
schema.
4.1.2 Guidance on use of conditional fields in the developers table
The IEC 62474 developers table includes a column (Obligation column) that indicates whether
a specific data field (element or attribute) is mandatory or optional. Some data fields are listed
as conditional. These fields are mandatory under certain material declaration conditions,
optional under other conditions. A conditional obligation may also cause an element or
attribute to become not applicable under certain conditions and therefore it may not be used
in that particular instance.
For example, the “identifier” attribute within the ProductID class is listed with a conditional

obligation. If the ProductID is used to identify the product at the top of the material declaration

hierarchy, then the identifier information is mandatory and must be provided by the user in the

material declaration. However, if the ProductID is used in declaring a product part that is

lower in the declaration hierarchy, this identifier information is optional.

There are a few other data elements and attributes that are also listed with a conditional

obligation. The Mass, MassPercent, and MatMassPercent elements have particularly complex

conditional provisions that must be carefully reviewed to ensure correct implementation.

4.1.3 Guidance on use of mass and mass percent fields

IEC 62474 specifies that a declaration is required to report either mass or mass percent, but
not both. This is important for data quality purposes as only one data field is variable and the
second data field is a calculated value.
If both the mass percent and the mass are declared, but due to errors the calculation does not
correspond to the reported mass, then the receiver of the material declaration will not know
which number is the correct one to use.
A general rule of thumb is to report using mass percent when reporting product families (e.g.
ICs, resistors, capacitors, etc) which contain multiple products in one declaration, but to use
mass when reporting assemblies or finished goods when a single product is declared.
Reporting concentrations (mass percent) for product families provides sufficient data for the
receiver of the declaration to correctly calculate the mass of each product in the family in their
IT software system tools, while streamlining the number of material declarations to be
exchanged between the two companies.
4.1.4 Calculating mass percent
In the material declaration, either mass or mass percent for the substance, substance group,
material or product part can be used.
Many laboratories report concentrations in ppm. One ppm means 1 part in 1 000 000 like
parts, such as grams to gram basis. ppm is converted to mass percent for such cases by the
formula Mass percent = X ppm / 10 000.
See Table 1 for conversion from ppm to mass percent.
Table 1 – Conversion table from ppm to mass percent
Percent (%) ppm = (mg/kg)
0,000 1 %         1
0,001 %        10
0,01 %       100
0,1 %      1 000
1,0 %     10 000
10,0 %   100 000
100,0 %  1 000 000
With one justified exception, mass percent is always referring to the next higher level in the
product hierarchy that is declared. This means that mass percent will refer to the material,
product part or product. The exception is that if a substance is assigned to a substance group
in the declaration (see IEC 62474:2012, 4.2.3 a), 4.3.4 a) and 4.3.5 a)), the mass percent
refers to material (if declared), product part (if declared) or to the product. The mass percent
of a substance is never calculated based on the mass of the substance group. Declaring a

– 12 – IEC TR 62474-1:2015 © IEC 2015

substance as a mass percent of the substance group can cause errors and therefore it is not

allowed in IEC 62474. This is stated in the relevant requirements included in IEC 62474:2012,

4.2.3 c), 4.3.4 c) and 4.3.5 c).

This deviation from the generic rule ensures that the recipient of a material declaration is able

to interpret the data correctly under any combination of base and optional reporting. This is

necessary to cope with situations where a declarable substance group has a reporting

requirement that is based on materials (e.g. homogeneous material). The situation is further

complicated when only a part of the compound (e.g. the lead in lead/lead compounds) is to be

declared. As some substances within the substance group may be unknown, the information
on percentage of the declared substances within the substance group cannot be
unambiguously correlated to the mandatory material mass percent declaration, and as a

consequence a further transfer of this information would not be of use.
As a consequence, the declaration of mass percent of a substance within a substance group
is not allowed in IEC 62474. To secure that the voluntarily provided declaration of a
substance is useful for any follow-up declarations, its mass or mass percent of the material (if
declared), product part (if declared) or product is needed.
To convert from mass to mass percent, one divides the mass of the substance or substance
group by the mass of the product, product part or material and then converts to percent.
Mass percent = mass of substance/mass of product, part or material × 100 percent.
The only time the MatMassPercent data field is used in the XML file is when the IEC 62474
database has a mandatory reporting threshold at the material level. For all other instances,
either the Mass or the MassPercent data field should be used in the XML file.
4.1.5 Interpretation of reporting threshold for declarable substances and declarable
substance groups
For most of the declarable substance and declarable substance group entries in the
IEC 62474 database, the reporting threshold is based on the mass percent of the product.
This is represented by a reporting threshold that is listed as "0,1 mass percent". The
reference to the mass of the product that is declared is implied in this threshold. However,
there are declarable substances and declarable substance groups that have a reporting
threshold with a different calculation basis. The EU RoHS declarable substance groups are
examples that use the mass of the homogeneous material as the basis for calculation. If the
reporting threshold refers to something other than the product (such as a material or a
product part like a battery), this is indicated in the IEC 62474 database.
4.1.6 Guidance on declaring a substance that belongs to two different substance

groups
A material declaration that conforms to IEC 62474 requires that a declared substance with a
mandatory reporting requirement must be assigned to its respective declarable substance
group with a mandatory reporting requirement, if the declarable substance group is declared.
The requirement “such substances shall be assigned to the substance group”is specified in
IEC 62474:2012, 4.2.3 a) and 4.3.4 a).
In most material declarations this is straightforward. However, since the establishment of
IEC 62474, several corner cases have emerged with a declarable substance fitting into two
declarable substance groups. For example, the REACH SVHC substance “Lead sulfochromate
yellow” creates such a situation. The declarable substance groups “Lead/Lead Compounds”
and “Chromium (VI) Compounds” are both relevant. "Lead/Lead Compounds” and “Chromium
(VI) Compounds” need to be declared if they are present at or above the reporting threshold
for each homogenous material. However, it is not possible in an XML file (by the design of the
XML schema) to assign the same occurrence of “Lead sulfochromate yellow” to both
substance groups simultaneously even if the Lead sulfochromate yellow triggered the

declaration of both declarable substance groups. Reporting this occurrence under both

Lead/Lead Compounds” and “Chromium (VI) Compounds” would incorrectly double the total

amount of Lead sulfochromate yellow and should be avoided, too.

Several possibilities arise for assigning the substance group in such situations. In the case of

Lead sulfochromate yellow, the responder (supplier filling out the material declaration) needs

to select one of the respective declarable substance groups and assign the substance to it.

Regardless of which declarable substance group is selected, the responder still needs to state

the presence of the other declarable substance group if it exceeds the threshold.

4.2 Flexibility of IEC 62474
4.2.1 Overview of material declaration features
Beyond the minimum declaration requirements specified in IEC 62474:2012, 4.2, base data
requirements and detailed data requirements as per the IEC 62474 XML schema, users have
significant flexibility in providing additional information that is useful in material declaration
exchanges up and down the supply chain.
4.2.2 Flexibility of declaring substances and substance groups at different levels
within the declaration
Users have flexibility as to how substances and substance groups are declared within the
hierarchy of the material declaration created in the XML file. For example, a user may
voluntarily declare the material for some substances; whereas other substances (such as EU
REACH SVHCs) may be represented as reporting directly into the product. This flexibility is
illustrated in Example 6 (see 5.7). If there are any restrictions on how a declarable substance
or declarable substance group is to be reported; this information will be provided in the
reporting threshold on the IEC 62474 database.
4.2.3 Declarable substances in a material declaration
4.2.3.1 General
The declarable substances and declarable substance groups in IEC 62474 are central to the
declaration. If they are present in the product, and meet or exceed the reporting threshold for
that particular application, it is required that these substances and substance groups are
identified in the material declaration if they have a mandatory reporting requirement.
Otherwise the declaration does not fulfil the requirements of IEC 62474. There are two
specific situations that are sometimes overlooked and deserve additional discussion in this
guidance document. These are trade secrets and substances with a CAS number that
contains other substances, which are discussed below.

4.2.3.2 Trade secret
Suppliers might have special alloys or compounds that are central for the function and where
the supplier does not want to disclose the exact composition.
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