The 7 most important questions on material compliance in device and machine manufacturing

Katrin Schneikert: Material compliance is the term used to name the adherence to all relevant regulations that affect the use of materials and substances, e.g. in products – whether these are laws and comparable regulations or requirements arising from customer contracts. Corresponding regulations now exist worldwide and while some are very product- and industry-specific, others apply in a very general way and are not dependent on the industry.

Katrin Schneikert: No matter how different the devices and machines are in their function and design, the requirementsprofile for material compliance is just as diverse. In most cases, the REACH regulation is relevant in the EU, and in some cases the requirements of the RoHS directive apply in addition. But even still less-known regulations such as the POP regulation or theF-Gas regulation, for example, may become relevant in addition to numerous other regulations. Depending on components and compositions, substance restrictions deriving from lex specialis such as the Battery regulation may apply, too. The important first stepis therefore always to get an overview of the requirements that are actually relevant for your own product – and to keep this overview up to date. Material compliance is very dynamic and without a close look at developments, you quickly slip into an unadvisablereactive handling of your duties.

Katrin Schneikert: In addition to observing substance prohibitions and restrictions, material compliance also includes, for example, information, reporting and labelling requirements. Without effective material compliance management, which includes the identification and control of the substances used, material compliance is more or less left to chance. Since material compliance is not a ‘nice to have’, but a market access requirement, a good understanding of the requirements and the product is needed for appropriate handling. In addition, a solid data structure, good supply chain communication and efficient information handling are basic requirements. Without appropriate processes, this is hardly feasible.

Katrin Schneikert: First and foremost, material compliance is always a question of risk management, which maintains a company's market share – in this function, it primarily serves to avoid sanctions such as fines or sales bans. In addition, however, an efficient and, above all, proactive approach to material compliance often also creates opportunities for the company. These opportunities range from driving product innovation and competitive advantage to faster entry into new markets. Last but not least, material compliance is also repeatedly the subject of companies' reporting obligations, such as in the context of CSRD or the EU taxonomy – here, the improvements achieved, for example in the course of a “product detox”, can also be made transparent to the outside world.

Katrin Schneikert: On the one hand, legal requirements are becoming more and more complex worldwide and the necessary expertise more specialised and demanding. The fact that material compliance is a cross-sectional issue involving various departments is also often a challenge. And finally, material compliance is an ongoing process that requires a constant effort to procure, maintain and use the necessary information and data. This should not be underestimated.

Katrin Schneikert: Material compliance is a form of sustainability that aims to protect resources, the environment and health. The urgently needed transformation from a linear to a circular economy is inconceivable without material regulations. Topics such as the use of recycled materials, their handling in recycling or possibilities for reuse require an ever more precise knowledge of the material composition of the products, which ultimately determines their suitability for such circular measures. Sustainability is therefore one of the most important drivers of material compliance.

Katrin Schneikert: Communicating the relevant material information in the supply chain is a key element of successful material compliance management. The information requirements range from the presence of certain substances to the geographical origin of material and instructions for safe use and disposal. A common understanding of the requirements is helpful here and often requires a change in thinking, in which suppliers are seen as compliance partners. This is often easier in OEM constellations than, for example, when purchasing ‘catalogue goods’ from a distributor – and however diverse supply chains are, the same applies here once again: there is no ‘one-size-fits-all’ solution in material compliance.