RMI Publishes CMRT Version 5.12

On April 26, the Responsible Minerals Initiative, RMI, released the newest version (v. 5.12) of the Conflict Minerals Reporting Template, CMRT. This is the 20th version, the fifth release at version 5, and the first update since CMRT v. 5.11, released on April 27, 2018.

The major updates to this version of the CMRT are the correction of bugs and errors, enhancements that do not conflict with IPC 1755, updates to the ISO short names for countries, states, and provinces, and regular maintenance updates to the smelter lists.
Updated smelter lists and smelter details (along with the latest version of the CMRT) may be found at http://www.responsiblemineralsinitiative.org. The next update to the CMRT is anticipated for Spring of 2020.

The new CMRT provides an opportunity for corporations and individuals collecting CMRT data as part of their due diligence surrounding a reasonable country of origin inquiry (RCOI) for SEC Reporting. Q Point adopts the stance that data provided from the latest version of the CMRT indicates updated information. That is to say, a CMRT v. 5.01 contains potentially out-of-date information when compared to a current CMRT (v. 5.12).

Corporations and individuals may use the new CMRT as a mechanism for gathering updated conflict minerals data and improving overall data collection from their suppliers. Alerting suppliers to the new CMRT may lead to a discussion that sets expectations for routine updates and the use of the latest CMRT version. Exclusive use of the new CMRT will produce Form SD filings with the SEC that will show data received in the current year after April 26, 2019. This will demonstrate the necessary due diligence that is a hallmark of reasonable country of origin inquiry (RCOI). Also, any effort in communicating a requirement and expectations to a supplier can be similarly used in the Form SD.



On January 15, 2019, ECHA added 6 new substances of very high concern (SVHC) to the REACH candidate list. The current SVHC list is now at 197 substances. The new SVHC and common usage is found in the table below.

As REACH continues to update and evolve, it is very important to have the ability to determine individual component compliance in a real-time environment with access to the latest compliance information from your suppliers. Of similar importance is the ability to have a direct communication link to the contacts at your suppliers who author and provide the compliance data that you need. Green Data Exchange provides this today.

Please continue to check the Q Point Technology Blog for recent news on regulatory changes, including REACH updates.


Green Data Exchange Custom Substance List Feature

Material content reporting poses a difficult challenge to many manufacturers. Specific regulations have changed in both the scope of materials covered (RoHS added 4 new substances) and the scope of how the regulation should be interpreted (REACH offers new definition of an ‘article’). In this ever-changing and compulsory setting, there are further complications from emerging regulations and customer requirements for specific material usage. These requirements are passed along to suppliers and some statement of compliance or quality agreement is generally sought.

Full material disclosure is only as good as the ability to search for and recognize specific substances quickly, identifying “at-risk” products and suppliers, and to use the data as proof to a customer who is asking for specific details on material use.

Green Data Exchange (GDX) now offers customized searching of substances and substance groups. You can use a pre-loaded list of substances to determine any usage of particular substances, whether regulated or not. This includes the ability to load a customer’s restricted materials list in order to check and maintain compliance to customer specific requirements. Finally, any restricted substance list can be added to GDX and assessed against existing material data.

Any custom substance list may be added. Lists can also be edited to add or remove substances as requirements change and adapt. Also, applications need not be limited to material content compliance. You can now use GDX to see where specific substances are in your products in order to determine information on potential tariffs, to compare potential replacement parts for material breakdown, to identify different manufacturing streams by substance, and much more.

The new feature works seamlessly with the existing GDX filters on the parts tab. This affords the ability to review restricted substances along with other part details like lifecycle information in order to determine if an action needs to be taken. You can also evaluate a specific product or product family against the restricted substance list by using the existing product compliance module and filters.

As new substances and regulatory substances lists emerge, GDX substance lists will be updated to reflect the latest changes. For example, the “REACH SVHC Candidates” list will be updated with the most recent SVHC Candidate List additions.

To learn more about this feature and others that GDX offers, please review our website.

ECHA Plans Database on Articles Containing Candidate List Substances

On July 11, 2018, ECHA announced plans for a new database for declaration of information related to articles containing Candidate List Substances. Declarations would be submitted by companies “producing, importing, or selling articles that contain Candidate List substances.”

For use by waste operators and consumers, this new database is being established in accordance with recent updates to 2008/98/EC, the Waste Framework Directive. Changes to the Waste Framework Directive passed on May 22, 2018 and set new targets for reuse and recycling of municipal waste. The database should “help waste operators in treating waste and recycling materials.”

Intention of the database is to help inform consumers to make safer choices, driving safe substitutes to market and “improve the risk management of chemicals during waste recovery” and “promote non-toxic material cycles.”

Current plans indicate the creation of the database by the end of 2019 with companies submitting data by the end of 2020. Note that if you are already using Q Point’s Green Data Exchange, you are already collecting the data and information that you would need to declare information on the use of SVHC in your articles.

Q Point will continue to follow developments on the new database and will post updates to this blog. For companies looking to collect data on Candidate List substances and usage within their own supply chain, please see our website for more details on Q Point’s solution, Green Data Exchange. For more information on the database, please see ECHA’s press release here or information on the Waste Framework Directive here.

Lead in Glass and REACH 191

ECHA has added lead (CAS No.: 7439-92-1) to the REACH Candidate List of substances, as of 27 June 2018. However, the way in which lead is used in your products may exempt it from the notification requirement of REACH, particularly if the lead is used in an application of a glass or ceramic frit. This article examines RoHS exemption 7(c)-I, currently renewed through 21 July 2021, REACH Annex V and its guidance from November 2012, as well as recent statements and positions from glass and ceramic manufacturers.

RoHS exemption 7(c)-I states the application of lead in the following is exempted.

Electrical and electronic components containing lead in a glass or ceramic other than dielectric ceramic in capacitors, e.g. piezoelectronic devices, or in a glass or ceramic matrix compound.

Based upon this exemption, any manufacturer using lead in this application would cite the exemption 7(c)-I on an EU RoHS Declaration of Conformity. However, the application of lead in this scenario would not require notification to customers on the use of lead as an SVHC for REACH. To understand why this is the case, let’s look at REACH Annex V.

Annex V of the REACH Directive lists thirteen categories of substances for which registration of the substance with ECHA is not necessary. There are, however, conditions to be met in order to claim the exemption. Criteria for meeting the conditions vary by category. Per the guidance on Annex V, published in 2012, but cited by ECHA as recently as May 2018, the criteria for glass and ceramic frit is that it must not meet the criteria for classification as dangerous according to Regulation (EC) No 1272/2008 which replaced the fully repealed Directive 67/548/EEC and Directive 1999/45/EC.

The rationale for the exemption is based upon the characterization of glass as an UVCB substance (unknown or variable composition, complex reaction products or biological materials). The guidance also suggests that glass “can best be defined through its starting materials and production process” for the purposes of legislation. Furthermore, the raw materials used in manufacturing a particular glass “meet the definition of intermediates inasmuch as they are transformed by synthesis into…glass.” This is based upon EU Court case-law found here. To this end, any glass or ceramic frit that does not possess significant hazard properties is exempted from REACH substance registration, thus precluding it from evaluation and further actions under REACH including notification of its use in articles.

Recent positions reiterating the exemption of glass have been stated by glass manufacturers and their associations. Glass Alliance Europe has published information detailing this position as well as many citations supporting the position of no notification on the use of lead for 7(c)-I exempted use of lead. Per Glass Alliance Europe there is “no obligation to notify under Art. 7(2) of REACH, nor to communicate information down the supply chain under Art. 33 of REACH. This was confirmed in ECHA Q&A – ID 1218 – 12/09/2016 relating to boron compounds.” Further, a prominent glass supplier in Germany states that as their “products consist mainly of glass and glass, as a substance, is not included in the Candidate List, there are no information duties under [REACH].”

To stay up to date with ever-changing regulations, obtain the data you need, and communicate in a real-time environment with your suppliers and customers for compliance information, please consider Green Data Exchange. To learn more, visit the Q Point Technology website and follow our corporate blog for the latest in news relative to material content compliance.

New Substances Considered for RoHS – RoHS Pack 15

The addition of seven new substances to the RoHS Annex II restricted substance list is being considered. Per article 6 of 2011/65/EU, restricted substances are to be periodically reviewed and Annex II is to be amended based upon “a thorough assessment.” Most frequently, this annex was updated to include 4 phthalates which will be enforced beginning in July 2019.

The “Study on the review of the list of restricted substances and to assess new exemption request under RoHS 2 – Pack 15,” conducted by Öko Institut & Fraunhofer Institute, sets out to update methodology for the “thorough assessment” of new restricted substances and then perform the assessment on the seven substances considered for inclusion.

The seven substances being considered are:

As an additional task to the assessment of the above substances, an evaluation of potential exemptions is being conducted.


To follow along with the project and to see relevant project documentation, please see http://rohs.exemptions.oeko.info/


As new substances are added to regulations, customers will need to determine their impact, both internally and upon the supply chain. Some stakeholders may begin inquiring about the presence and use of these substances within their supply chain immediately. In order to handle requests on emerging hazardous substances, you should be able to quickly request substance use information and check against existing data in a real-time environment. Green Data Exchange (GDX) will help you to respond to these requests today. By addressing any customer’s concerns over the use of emerging hazardous substances with fast and accurate responses, you can improve your own supplier performance score and obtain a competitive advantage over other suppliers.


In a review of recent history and new substance inclusion, Q Point notes that the process to include the 4 phthalates (the most recent change to RoHS) in Annex II began in 2012 and was not completed until June 2015, with an enforcement date of July 21, 2019. At this point, it is very likely that the Pack 15 substances are, at least, a couple of years away from enforcement. As new information is released, this blog will post relevant information and updates.


To learn more about solutions for material content restrictions, such as RoHS, please check out Green Data Exchange, GDX, at www.qpointtech.com


On June 27, 2018, ECHA added ten new substances of very high concern (SVHC) to the REACH candidate list. The SVHC list is now at 191 substances. The new SVHC and common usage is found in the table below.

SVHC CAS No. Reason for Inclusion Common Usage
Benzene-1,2,4-tricarboxylic acid 1,2 anhydride

trimellitic anhydride; TMA

552-30-7 Respiratory sensitizing properties A reactive chemical compound used in the esterification of alcohols.




191-24-2 PBT



Research substance used to make dyes, plastics, pesticides, explosives, pharmaceuticals, bile acids, cholesterols, and steroids.




541-02-6 PBT



Emollient used in cosmetics, including sunscreen and hair care products.


Dicyclohexyl phthalate



84-61-7 Toxic for reproduction


Endocrine disrupting properties


Substance used for manufacturing adhesives and sealants, coating products, fillers, putties, plasters, modelling clay, finger paints, non-metal-surface treatment products, inks and toners, polishes and waxes, polymers and textile treatment products and dyes.


Disodium octaborate


12008-41-2 Toxic for reproduction




540-97-6 PBT



Substance used in washing & cleaning products, polishes and waxes, cosmetics and personal care products and pharmaceuticals.





107-15-3 Respiratory sensitizing properties A substance used in the manufacture of fuel additives, bleach activators, chelating agents and corrosion inhibitors




7439-92-1 Toxic for reproduction Used in metal, especially copper alloys and stainless steels. Commonly found in paints, construction materials, flooring, leather products, and electrical & electronic equipment.




556-67-2 PBT



Found in cosmetics and personal care products, washing & cleaning products and polishes and waxes.


Terphenyl, hydrogenated


61788-32-7 vPvB Heat transfer medium, can also be used as a plasticizer.


As REACH continues to update and evolve, it is very important to have the ability to determine individual component compliance in a real-time environment with access to the latest compliance information from your suppliers. Of similar importance is the ability to have a direct communication link to the contacts at your suppliers who author and provide the compliance data that you need. Green Data Exchange provides this today.

Please continue to check the Q Point Technology Blog for recent news on regulatory changes, including REACH updates.