OEMs and EMS providers are bombarding component suppliers with unique requests for information and, in many cases, are getting inadequate responses. Suppliers, in turn, complain that responding to each customer's unique request for data consumes considerable time and resources.

What's needed is a standard for materials declaration on which everyone, including the European Union and its 25 member countries, can agree, industry sources said.

Well, the wait may be over, according to Richard Kubin, chairman of IPC's Declaration Process Management Subcommittee and vice president of product life cycle management solutions at E2open. Last month, Kubin's subcommittee released a draft materials declaration standard, data model and form for review by the industry. He expects the formal standard to be released in August or September but purges companies to start using the data model now.

"We have eight to 10 major multinational companies committed to using the form, which equates to well over 10,000 suppliers," said Kubin. "Once we get some of these large companies using it, it will really take on a life of its own."

Still, many suppliers are behind the curve, and there is much work to be done to educate them on the requirements of RoHS compliance. It's the OEMs' responsibility to communicate the requirements because they bear the liability for noncompliance. "You are only as strong as your weakest link," Kubin said.

The IPC data model may prove to be an ideal mechanism for communicating with suppliers. Kubin suggests that OEMs e-mail the form to their suppliers, tell them this is how they will collect the information, and refer them to resources on the IPC Web site for instructions on the standard and data model behind it.

Of course, collecting the data and doing the necessary due diligence is only one weapon in the OEM's arsenal. The other change required is in the language in all master contracts and procurement agreements specifying RoHS compliance on the part of the supplier.

"Companies need to make sure that the language in the agreements clearly supports their requirements around compliance," said Kubin. "The audit trail behind the declaration form reinforces this. The form can be digitally signed so it becomes a record from the supplier as to their declaration."

The time to act is now. "There is no time to hold off," said Kubin. "The data model is there, the XML that supports it is consistent with the RosettaNet PIPs [partner interface processes], and it's a pretty consistent set of data fields.

"So as far as establishing an internal database and tying it into internal systems, that can be done now."