Training: Material
Compliance Requirements
for Cummins Suppliers
Agenda
 Introduction
 Cummins’ Approach
 Supplier Requirements
–
–
–
–
Full Material Disclosure (FMD)
FMD Format
FMD Reporting Tools
Reference Material
 Regulations Driving Requirements
– RoHS Basics
– REACH Basics
– ELV Basics
 Next Steps
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Introduction
Depending on the business, market and product,
companies face different rules of product compliance.
Some rules such as RoHS, REACH and ELV require
compliant supply chains. This means that even though
they come from the EU, they have global implications.
In order for Cummins to continue to sell products
around the globe, we must be able to demonstrate our
products are compliant.
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Introduction (cont..)
 This presentation is intended to inform you about the
regulatory requirements of Cummins and what we
require of you as a valued supplier of parts /
components
– NOT trying to mandate how you, as a business, comply
with the relevant laws for your own products (if in scope) –
if in doubt, please seek professional advice
– Failure to fulfil these compliance requirements may lead us
to seek alternative solutions
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Cummins’ Approach
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Cummins’ Approach
 Cummins products + relevant markets + legislation =
challenging and complex compliance requirements
 Our Mission: Demanding that everything we do leads to
a cleaner, healthier, safer environment
 To comply and execute our mission, we need to know
what is in our products
 May need to perform supplier audits and testing, as
needed, depending on product risk
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Supplier Requirements
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Supplier Requirements:
Full Material Disclosure
 Provide a full material disclosure (FMD) in industry
standard format within 45 days of our request.
 What can go wrong?
– If we don't have the information, we can't provide compliance
information to customers and regulatory authorities, and our
market access may be limited.
– If a only partial declaration is provided, you will be required to
submit new declarations upon regulation changes, which can be
as frequent as every six months.
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Supplier Requirements:
FMD Format
 The full material disclosure must be declared using the industry standard
format, IPC1752A:
– http://www.ipc.org/ContentPage.aspx?pageid=Materials-Declaration
 This standard allows the information to be read by compliance databases,
which enables Cummins to provide a product compliance status report.
 If suppliers are unfamiliar with this standard, Cummins recommends three
other ways you can comply with this request:
1)
2)
3)

IMDS – Automotive applications only
BOMCheck
Anthesis Template
Additional guidance on these methods are described in the following
sections.
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Supplier Requirements:
FMD Reporting Tools
 The International Material Data System (IMDS) is used by suppliers worldwide to support the
automotive manufacturers (www.mdsystem.com).
– If you sell a product into the automotive industry, it is likely that you are already familiar with the IMDS.
– Unfortunately, other industries are not as fortunate to have a common tool. Therefore, for Cummins, nonautomotive components that are subject to RoHS and REACH, alternative methods of reporting are
necessary.
– Caution: Hewlett Packard Enterprise (HPE) takes the IMDS Terms of Use (ToU) seriously. If you have any
doubt regarding adherence to the ToU, contact HPE.
– If you are unsure if your part is used in an automotive application, please send an email to
supplier.compliance@cummins.com.
 If you receive a request specifically asking to use IMDS, please submit data to
Cummins ID 3664.
– While submitting the MDS, supplier must include the Cummins part number and six-digit Vendor ID in order
for the data to be accepted.
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Supplier Requirements:
FMD Reporting Tools
 BOMCheck
– BOMCheck is an online resource for sharing product compliant data which can be accessed
at www.bomcheck.net.
– Using BOMCheck benefits both suppliers as the supplier data for a single part number would
only need to be entered once, but can be shared with multiple customers.
– The cost for using BOMCheck is minimal:
• Free 90 trial
• Free for companies with total annual turnover of less than 3 million Euros
• Otherwise, only 300 Euros per year
– Creating a Supplier Account is easy. Click the green “Suppliers” button at the top, then click
the blue “Create a supplier account” button.
– There are several training opportunities (pre-recorded webinars, live training webinars, and
User Guides)
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Supplier Requirements:
FMD Reporting Tools
 Anthesis Spreadsheet
– This Excel tool can also be used to provide product compliance data.
– If you did not receive a copy of your parts list and spreadsheet, please e-mail the
Cummins Supplier Compliance team at the e-mail address following this
presentation.
– Tool Demonstration…
– Please refer to the Quick Start Guide for additional guidance.
– The Quick Start Guide and additional information may be found on the Cummins
Supplier Portal. A link to the Portal, by clicking the “Help” button, may be found
on the Products tab of the Anthesis spreadsheet.
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Supplier Requirements:
FMD Reporting Tools
 Anthesis Spreadsheet Common Errors
– Business Info Tab
• Select a Template Setting (Class A, C, or D)
• Enter your Company Name and Vendor ID as it appears in the Parts List
– Products Tab (For Class A, C, and D)
• Enter the Part Numbers as they appear in the Parts List
• Enter the weight and unit of measure for each part
– Query List Tab (For Class A)
• Create three rows
1.
2.
3.
EUROHS- 1506
EUROHS- 0508
EUREACH- 0117
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Supplier Requirements:
Reference Material
 Access the Supplier Portal site by either clicking here or
the Help button in the Anthesis template to reference the
following materials:
– Materials Compliance Requirements for Cummins Suppliers Presentation
– Anthesis Template
– Anthesis Quick Start Guide
 For questions not answered by the portal, please send
an email to supplier.compliance@cummins.com
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Regulations Driving Requirements
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Regulations Driving Requirements:
RoHS Basics
The European Union’s
Restriction on Hazardous Substances
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Regulations Driving Requirements:
RoHS Basics
 What is RoHS?
– RoHS is an European Union (EU) legislation that restricts certain substances in
electrical and electronic equipment with the goal of reducing the environmental
impact of such equipment.
– It originally entered into force July 1, 2006 (2002/95/EC) and was later revised
June 8, 2011 (2011/65/EU) and entered into force July 3, 2013.
– The latest version of RoHS may be found here.
– Countries beyond the EU (China, Korea, India, etc.), have also adopted RoHSlike legislation.
– Many Cummins products are considered electrical and electronic equipment.
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Regulations Driving Requirements:
RoHS Basics
 Requires declaration that relevant products
placed on the market do not contain above
threshold level of certain substances
 Requires CE Marking
 Requires Declaration of Conformance
 Requires Technical Documentation
 Includes exemptions with expiration dates
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Regulations Driving Requirements:
RoHS Basics
 RoHS Substance Restrictions
– Substances restricted (Percentages indicate the max tolerated and are based on the
amount of the substance in a single homogenous material):
• Lead (0.1%)
• Mercury (0.1%
• Cadmium (0.01%)
• Hexavalent chromium (0.1%)
• Polybrominated biphenyls (PBB) (0.1%)
• Polybrominated diphenyl ethers (PBDE) (0.1%)
• Bis (2-ethylhexyl) phthalate (DEHP) (0.1%)
• Butyl benzyl phthalate (BBP) (0.1%)
• Dibuytl phthalate (DBP) (0.1%)
• Diisobutyl phthalate (DIBP) (0.1%)
– Some exemptions exists
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Regulations Driving Requirements:
RoHS Basics
 Exemption Examples:
– Lead as an alloying element in aluminum containing up to 0.4% lead by
weight is permitted (6b).
– Copper alloy containing up to 4% lead by weight is permitted (6c).
– Lead in high melting temperature type solders (i.e. lead based solder
alloys containing 85% by weight or more lead) (7a).
 Keep in mind that exemptions have expiration dates!
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Regulations Driving Requirements:
RoHS Basics
 What is a Homogenous Material?
 Either:
– A material with a uniform composition throughout
– A material that consists of a combination of materials, that cannot be disjointed or separated into different
materials by mechanical actions such as unscrewing, cutting, crushing, grinding or abrasive processes.
 EACH homogenous material must be compliant. If not, the whole product is not
compliant.
 Examples: plastic computer screen cover, a copper wire inside a cable, solder part of
a solder joint, material layer in a bearing.
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Regulations Driving Requirements:
RoHS Basics
 Common homogenous materials containing restricted substances:
– Lead – Solders, termination coating, paints, pigment, PVC stabilizer
– Cadmium – Coatings, solders, semiconductors, contacts, PVC stabilizers,
pigments
– Mercury – Fluorescent lamps, batteries, sensors, relays
– Hexavalent Chromium – Coatings to prevent corrosion (on zinc, aluminum or in
paints).
– PBB, PBDE – Flame retardant in certain plastics
– DEHP, BBP, DBP, DIBP – Plasticizers in certain plastics and cables
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Regulations Driving Requirements:
RoHS Basics
 Products that were compliant to RoHS 2002/95/EC may not
be compliant to RoHS 2011/65/EU.
 Even products that were compliant to RoHS 2011/65/EU in
the past, may no longer be compliant, if the exemption has
expired!
 It is critical that suppliers provide Cummins with up-to-date
compliance information - New substances may be added to
RoHS and exemptions expire, which may change the
compliance status of your products.
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Regulations Driving Requirements:
REACH Basics
The European Union’s
Registration, Evaluation, Authorization and Restriction
of Chemicals
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Regulations Driving Requirements:
REACH Basics
 What is REACH?
– REACH is an European Union (EU) legislation designed to protect human health
and the environment. It entered into force in June 2007.
– Aims to monitor and restrict the movement of hazardous chemicals through the
EU, including substances in preparation form and incorporated into articles
– It replaces 40 years of old EU chemical legislations by compiling them into one
– It contains 849 pages of text, plus tens of thousands of pages of technical
guidance.
– Applies to EU legal entities but many requirements flow down the supply chain.
– Requirements apply to all industries and vary depending on the product
(substance/material or article)
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Regulations Driving Requirements:
REACH Basics
 Registration – A substance must be registered with the European Chemicals Agency
(ECHA), if the substance is intentionally released from an article > 1 ton per year.
 Authorization – Banned substances, will need special authorization in order to
continue to be allowed used in the EU.
 Potential banned substances are taken from the Candidate List (aka: Substances of
Very High Concern, SVHC) list.
 Companies using SVHCs may have Notification (to ECHA) and/or Communication (to
Customers) requirements depending on the amount of the SVHC.
 It is critical that suppliers provide Cummins detailed information regarding the amount
of any SVHCs in their products. This information is needed to determine Cummins’ or
Cummins’ customers’ Communication and Notification obligations.
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Regulations Driving Requirements:
REACH Basics
 What is an article?
– An object which, during its production, is given a special shape, surface
or design which determines its function to a greater degree than its
chemical composition.
OA5 Ruling – “Once An Article is Always An Article”
Threshold limits are now calculated at the smallest component with an
engineered shape.
Weight of
substance
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Concentration
Level
Weight of
substance
=
Concentration
Level
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Regulations Driving Requirements:
REACH Basics
 More on SVHCs…
– SVHCs that are added to the Candidate List are those that are a candidate for
elimination. These include: carcinogens, mutagens, reproductive toxins,
persistent, bio-accumulative toxins, very persistent and very bio-accumulative
toxins, endocrine disruptors, and substances of equivalent concern.
– The Candidate List continues to grow and currently numbers 173 SVHCs.
– The current list of SVHCs may be found here.
– We are requiring suppliers to provide FMD so that the supply chain does
not need to be re-surveyed every time a new SVHC is added to the
Candidate List.
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Regulations Driving Requirements:
ELV Basics
The European Union’s
End-of-Live Vehicles Directive
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Regulations Driving Requirements:
ELV Basics
 What is ELV?
– ELV is an European Union (EU) directive that restricts certain substances in automobiles goal
of reducing the environmental impact at the end of the vehicles useful life.
– It originally entered into force September 18, 2000 (2000/53/EC) and set the stage for other
product compliance regulations such as RoHS and REACH.
– ELV is applicable to automobile manufacturers that manufacture or import automobiles into
the EU. However, most all global automotive manufacturers have adopted the requirements.
– The Cummins products, used in automobiles, must comply with the ELV to meet their
customer’s requirements.
– The current ELV directive may be found here and current exemptions may be found here.
– As the burden of ELV compliance is on the automotive manufacturers, the automotive
manufactures agreed upon a common tool (IMDS) for which their supply base could provide
their material declarations.
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Next Steps
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Next Steps
 Respond to our requests for information in a timely fashion (45 days from
request)
– Upon submission of material declaration, look for a system-generated email notification of
acceptance or rejection
 Identify a Product Compliance contact at your organization and send the contact
information to supplier.compliance@cummins.com
 Cascade requirements to your supply chain
 Include requirements as part of your terms and conditions
 Continuously monitor product compliance regulations
 Join industry groups to help keep your company up to date and/or consult
professionals if you require assistance in your compliance efforts
 For further questions, send an email to supplier.compliance@cummins.com
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