Why Do Material Manufacturers Take Months to Release Updated Compliance Declarations After New Standard Revisions

[Jana Kumari]

Hi everyone,

I am a QA Engineer from a plastic injection molding industry.
I’m trying to understand the internal process that material manufacturers follow when preparing regulatory declarations such as REACH, RoHS, CMRT, EMRT, PFAS and other compliance documents.
Whenever there’s a new revision to one of these standards (for example, when CMRT 6.5 and EMRT 2.1 was released), it often takes material makers several months, sometimes around 3-4 months before they can provide the updated declarations to customers.
From the customer side, this delay creates a lot of pressure, since our own customers keep chasing us for the latest declarations.

• What are the steps or procedures involved in updating these declarations?
• Do manufacturers need to perform testing to confirm the composition of substances when a new revision is released?
• If testing is required, do they test only for the newly added substances, or do they have to retest for existing substances as well?
• What are the typical data collection or supplier communication processes that might cause these delays?

I’d really appreciate any insights from those who work in material compliance, supplier quality, or environmental regulations. Understanding this workflow would help me explain the situation better to our customers while waiting for updated declarations from our material suppliers.
Currently, we’re struggling to get the updated declarations, and the customer is continuously following up — so any detailed explanation would be a huge help.

Thanks in advance!

 

[John Predmore]

What reasons do your suppliers tell you when you ask why the delay?

Also ask, Is there anything my company is doing that hinders the suppliers ability to give their customer what they ask? Sometimes you'd be amazed at the wisdom that can be gained by having a conversation, and that can go both ways.

[I remember a case when my process engineer asked this at the end of an hour-long supplier review, which led to a relatively simple design change. The customer's share was 10% cost reduction, which amounted to millions of dollar savings, just for having the courage and humility to ask an innocuous question.]

 

[Golfman25]

Hi everyone,

I am a QA Engineer from a plastic injection molding industry.
I’m trying to understand the internal process that material manufacturers follow when preparing regulatory declarations such as REACH, RoHS, CMRT, EMRT, PFAS and other compliance documents.
Whenever there’s a new revision to one of these standards (for example, when CMRT 6.5 and EMRT 2.1 was released), it often takes material makers several months, sometimes around 3-4 months before they can provide the updated declarations to customers.
From the customer side, this delay creates a lot of pressure, since our own customers keep chasing us for the latest declarations.

• What are the steps or procedures involved in updating these declarations?
• Do manufacturers need to perform testing to confirm the composition of substances when a new revision is released?
• If testing is required, do they test only for the newly added substances, or do they have to retest for existing substances as well?
• What are the typical data collection or supplier communication processes that might cause these delays?

I’d really appreciate any insights from those who work in material compliance, supplier quality, or environmental regulations. Understanding this workflow would help me explain the situation better to our customers while waiting for updated declarations from our material suppliers.
Currently, we’re struggling to get the updated declarations, and the customer is continuously following up — so any detailed explanation would be a huge help.

Thanks in advance!

Short answer is they have better things to do. In your question you identified 5 standards which constantly need updating. You want them to do their due diligence which takes time.

 

[Jana Kumari]

What reasons do your suppliers tell you when you ask why the delay?

Also ask, Is there anything my company is doing that hinders the suppliers ability to give their customer what they ask? Sometimes you'd be amazed at the wisdom that can be gained by having a conversation, and that can go both ways.

[I remember a case when my process engineer asked this at the end of an hour-long supplier review, which led to a relatively simple design change. The customer's share was 10% cost reduction, which amounted to millions of dollar savings, just for having the courage and humility to ask an innocuous question.]

Thank you for the update.

It’s understandable that our major suppliers may need additional time for testing.They are our major suppliers, and the quantity we demand from them is quite substantial. However, it would be helpful if we could get more clarity on the specific types of testing they need to perform and the expected timelines.
Some suppliers have been unresponsive or only reachable through official websites.
Regarding suppliers who only release updates once a year, we would like to know whether there are any exceptions or interim updates that can be made to support our project timelines.

Appreciate if you could advise on below.

• Do manufacturers need to perform testing to confirm the composition of substances when a new revision is released?
• If testing is required, do they test only for the newly added substances, or do they have to retest for existing substances as well?