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Last updated: October 2026



Supplier Material Declarations (IPC-1752 and FMD)

A material declaration is a supplier's statement of what substances are in a part. RoHS limits apply to each homogeneous material - a single material that cannot be mechanically separated, such as a solder joint, a plating layer or a plastic housing - so declarations have to reach that level of detail to show compliance. Material declarations are the base layer of every RoHS, REACH and PFAS compliance program.

Types of declarations

  • Full material declaration (FMD) - lists every substance in a part by homogeneous material and mass, accounting for 100% of the part's weight. An FMD can be re-checked against any new restriction without going back to the supplier.
  • Query-based or partial declaration - answers yes/no against a specific list, such as the RoHS restricted substances or the REACH SVHC Candidate List, sometimes with concentrations for listed substances only.
  • Certificate of compliance (CoC) - a signed supplier statement that a part meets a named regulation, with no substance data behind it.
  • RoHS Declaration of Conformity (DoC) - the legal declaration made by the manufacturer of the finished product under Directive 2011/65/EU. It is not a supplier document, but it relies on supplier declarations.

IPC-1752 data exchange

IPC-1752 is the electronics industry's standard XML format for exchanging material declarations between suppliers and customers. IPC-1752A defines declaration classes that range from simple RoHS yes/no responses to full homogeneous-material composition, and IPC-1752B is its current revision. Because the format is machine-readable, declarations can be loaded directly into PLM and compliance software and rolled up across a bill of materials.

IEC 62474 Declarable Substance List

IEC 62474 is the international standard for material declaration in the electrotechnical industry. Its Declarable Substance List (DSL), maintained by IEC Technical Committee 111, consolidates the substances that must be declared under RoHS, REACH, the EU POPs Regulation and other regulations into one reference list, including PFAS groups. IPC-1752 declarations are aligned with the IEC 62474 list.

Declaration workflow

  1. Scrub the bill of materials - confirm manufacturer part numbers and identify which parts lack current declarations.
  2. Request declarations - prefer FMDs in IPC-1752 format; accept query-based declarations where FMDs are unavailable.
  3. Validate - check that masses sum to the part weight and that substance identities and CAS numbers are consistent.
  4. Roll up - aggregate part data to the product level to support the RoHS DoC, REACH Article 33 communication and SCIP notifications.
  5. Refresh - re-screen when the REACH SVHC Candidate List is updated, when RoHS exemptions expire and when suppliers change.

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