What is Full Material Disclosure

A Full Material Disclosure (FMD) is a detailed homogeneous level substance / material breakdown of a product, component or material. The FMD information helps determine product compliance against environmental regulations and directives such as RoHS, REACH, and Conflict Minerals.

Having Full Material Disclosures enables companies to speed up the process of processing and delivering compliance documentation and overcome supply chain disruptions. The approach of using FMDs instead of Certificates of Compliance (CoC), also makes it easier to manage changes to compliance regulations in the years ahead, so the compliance program is in a way ‘future-proofed’. FMDs can be created by the manufacturing companies for their own products by collecting the part level full material composition information starting from their downstream supply chain. FMDs can be used to demonstrate a wide variety of compliance requirements, whereas certificates of compliance are only for a specified compliance regulation, that too the current version.

Initially FMDs were used mainly by the electronics industry, but over time various other industries have adopted the FMD approach, to minimize the pressure on changing needs of diverse regulations worldwide.

Our FMD based compliance solutions provide:

  • Sourcing of Full Material Disclosure for off-the-shelf and custom parts covering various aspects such as, substance identifiers, substance weight, and substance level exemptions
  • Maximum coverage of compliance information from suppliers, leveraging our multilingual supplier engagement team
  • Validation of FMDs received from third party suppliers to identify any errors or mismatches in declarations
  • Centralized platform to store FMDs and generate reports, with integration options to ERP or PLM Systems

Benefits of Full Material Disclosure:

  • Complete product data: Provides full information on substance composition, eliminating any risks of surprise elements on the inside or outside of a product.
  • Be ready for future regulatory changes: Easy management of regulatory changes such as addition to Prop 65 list or REACH SVHC candidate list (ECHA updates the SVHC list once in every 6 months) or change in threshold levels for RoHS.
  • Eliminates lead time and supplier fatigue: With an FMD, there is no need to check with suppliers each time the regulatory requirements change.
  • Reliable documentation: An FMD acts as a reliable supporting document to validate the CoC / compliance declaration provided by the suppliers, and hence makes your compliance program more reliable.

The most feasible format to exchange the FMDs are XML formats. Different industries have adopted different international standards in this format. Each international standard has different capabilities, data requirements and industrial levels.

  • IPC-1752A: Developed to support the data exchange requirements of REACH and RoHS. This has 4 classes- Class A, Class B, Class C and Class D.
  • IPC-1754: This standard is for data exchange of Aerospace and defense. It has 3 different classes -Class E, Class F and Class G.
  • IEC 62474: Developed by International Electrotechnical Commission. This enables users to exchange 100% of product information in XML format. And, specifically cover the substance listed in DSL.