Standards & FormatsConcept

Material Declaration: Formats, Levels and Common Errors

Note: general educational information, not legal advice. Check the official source before relying on it.

The umbrella practice of reporting what substances and materials a product contains, so the supply chain can prove compliance. Depth ranges from a simple supplier statement up to a full breakdown.

Updated
2026-09-12

Overview#

A material declaration is how one company tells the next one what's inside a part. It is structured so that compliance can be checked rather than guessed.

Key point

There are three depths, increasing in detail and effort. A supplier statement answers whether the part complies. A substance-list declaration reports how much of each listed substance is present. A full material declaration covers everything. Pick the shallowest one that answers the question.

Why it exists#

No factory sees its whole supply chain. To prove a product meets RoHS, REACH, POP and the rest, each tier has to pass composition data up to the next. Material declaration is that hand-off. Standardising it (for example with IEC 62474 or IPC-1752A) is what makes the data reusable instead of a thousand bespoke spreadsheets.

The three depths#

1Supplier / contractual statement
A yes or no on a named rule set: "this part meets RoHS, and uses exemption X." Cheap, but it answers only one question and must be re-asked when the rules change.
2Declaration against a substance list
Reports the concentration of every substance on a chosen list (for example the IEC 62474 DSL or GADSL). Covers many rules at once.
3Full Material Declaration (FMD)
Every substance in the whole product, down to the homogeneous material. The most effort, and the most future-proof.
Supplier statementSubstance-list MDFull Material Declaration
Answers"Compliant with rule X?""How much of each listed substance?""What is everything made of?"
EffortLowMediumHigh
Covers new rules?Re-ask each timeIf the substance is on the listRe-check existing data
Know-how exposedNoneListed substances onlyFull recipe (can be partly anonymised)

How much should you declare?#

The honest answer is the shallowest depth that satisfies the law and your customer. Deeper declarations cost more to produce and reveal more of your recipe, but they age better. A practical pattern is to let each tier declare the layer it actually knows: materials, then components, then assemblies, then the finished product.

Tip

A Full Material Declaration is the only depth that survives a future restriction without re-surveying suppliers, because the data is already there. Many teams treat it as the long-term goal even if they start shallower.

Mandatory vs. worth-watching#

Not every substance you'd report is banned. Declarations carry two kinds of flag.

Must declare (obligation)

A declarable substance tied to a live rule, such as a REACH SVHC or a RoHS substance. Reporting is required.

Worth watching (interest)

A substance under review, such as one in a REACH CoRAP evaluation. It is not yet restricted, but reporting it now saves a scramble later.

A worked example (illustrative)#

Take a generic panel connector: brass pins with a tin coating, in a glass-filled plastic housing. Here is the same part declared three ways.

  • Supplier statement. "RoHS-compliant; lead in the brass is covered by an exemption." You learn nothing else.
  • Substance-list MD. Lists the lead, plus any other listed substance present, with concentrations. You can check it against several rules.
  • FMD. The brass alloy, the tin layer, the polymer, the glass fibre, the flame retardant, the pigment, every substance, every layer. You can answer any future question.

(Illustrative only, not real compliance data.)

Where the data formats fit#

IEC 62474 and IPC-1752A are the standard containers for all three depths. IPC-1754 extends them to whole articles. The reference list of what to declare comes from a substance list. Industry platforms such as BOMcheck collect these declarations from suppliers at scale, so the same data can be reused across many customers.

Which container you are asked for depends on who is asking.

FormatAsked for byCarries
IPC-1752AElectronicsXML in classes A to D, from a compliance answer up to a full declaration
IMDSAutomotiveA Material Data Sheet per part in a shared database, reportable content from GADSL
CMRT and EMRTAny chain touching conflict mineralsSmelters and country of origin for 3TG, extended to cobalt and mica
chemSHERPAJapanTwo formats, AI for articles and CI for chemical products, on the IEC 62474 DSL
Note

CMRT and EMRT are maintained by the RMI, not by a standards body, and they answer a sourcing question rather than a composition one. They sit next to a material declaration rather than inside it.

Where declarations go wrong#

Most rejected declarations are not dishonest. They are filed against the wrong part, or they are true about a list that has since moved.

What goes wrongWhy it breaks the declaration
Part numbers that do not matchThe customer's number, your number and the supplier's number are three strings for one part. A declaration filed against the wrong one is worse than none
Percentages that do not closeA full material declaration is meant to account for 100 % of the part's mass. One that does not is not a full declaration, whatever it is labelled
Substances identified looselyA trade name or an alloy grade where a CAS number was expected leaves the receiver guessing which substance was meant
Declarations that have agedThe Candidate List moved after the file was written, so the file is accurate about a list that no longer looks that way
Schema-valid but wrongA file can pass the published schema and still contradict the bill of material behind it
Caution

Schema validation and content validation are different checks. The first asks whether the file is shaped correctly, the second whether it says something true about the part. A tool that only does the first will pass a declaration that nobody can use.

Producing declarations in this format?

Pareo reads and writes supplier declarations in the common exchange formats, so your engineers stop re-keying them by hand.

See how it works
Learn 4 flashcards
Material Declaration: Formats, Levels and Common ErrorsMaterial DeclarationIEC 62474: Material Declaration for the Electrotechnical IndustryIEC 62474IPC-1752A: Material Declaration XML Format (Class A to D)IPC-1752AGADSL: Global Automotive Declarable Substance ListGADSLIPC: Association Connecting Electronics IndustriesIPCIPC-1754: Materials & Substances Declaration for Aerospace, Defense and Other IndustriesIPC-1754Declarable Substance: Obligation vs. InterestDeclarable SubstanceSubstance ListSubstance ListFMD: Full Material Declaration (Full Material Disclosure)FMDIEC 82474-1: Material Declaration, Part 1 General RequirementsIEC 82474-1CoRAP: Community Rolling Action PlanCoRAPAsset Administration Shell (AAS)AASBOMcheck: Supplier Database for RoHS, REACH and FMD DataBOMcheck
material declarationsupply chaindeclaration typesFMD