We are finding that a large portion of the parts that have "full material disclosure" in our database, contain one or more substances that are proprietary, generic or pseudo-substances. This brings up two fundamental issues:
· When a new REACh list is published there is nothing to drive us to seek an up to date REACh declaration or updated IPC1752A.
· There is no interaction between the RoHS and REACh declarations attached to the manufacturer’s part number.
When we receive an IPC1752A that lists a proprietary or pseudo-substance (with a “-“ or “SYSTEM” for the CAS#), there appears to be a tacit assumption in WPA that as of the date of the form there are no REACh SVHC’s in these substances. If the WPA user is also securing REACh and RoHS declarations at that time, importing the forms into WPA does cover a passing compliance verdict until the REACh candidate list is updated. Once it is, however, WPA does not flag the part as needing a new REACh declaration even though one of the proprietary or pseudo-substances may contain an SVHC. PTC has recognized this with Pre-Qualified parts, but not with parts that contain a proprietary or pseudo-substance.
Further, the only way to update the part is to upload an IPC1752A with all of the content data and the new REACh information. This is frequently cumbersome for those parts where the vendor supplies info in another format and we have to convert it. If there were some functional linkage between the RoHS and REACh declarations and the compliance verdict it would reduce the maintenance labor.