Our products are distributed worldwide and are affected by a multitude of legislation—both local and global. Driven by growing concern over the effects of hazardous substances on health and the environment, governments in every region have introduced regulations restricting the sale of products containing certain substances. These cover a broad range of products, including electronics. We continually monitor worldwide legislation, laws and regulations related to substances.
The EU RoHS2 Directive came into effect in January 2013. The Directive of the European Parliament and the Council of the European Union provides for the Restriction Of certain Hazardous Substances (RoHS) in electrical and electronic equipment (EEE), as amended by Delegated Directive (EU) 2015/863. Motorola Mobility products have complied with EU RoHS since the inception of the RoHS1 Directive (2002/95/EC), which came into force January 2003. Official EU Commission Guidance Document for RoHS2.
Registration, Evaluation, Authorisation and Restriction of Chemicals REACH requires companies involved in manufacturing or importing of chemicals (or products containing chemicals) to collect or generate data on the substances. It is designed to control risks to human health and the environment. Motorola Mobility maintains a list of products in accordance with these requirements.
EU Battery Directive (2006/66/EC) Governing material restrictions, marking, collection and recycling of batteries and accumulators.
China requires labeling and substance disclosure tables for certain products. Chinese regulators have released a catalog of products that is periodically updated, which identifies the products required to meet hazardous substances limits as well as the recycling requirements in China.
Motorola Mobility has a comprehensive program in place for tracking and reporting conflict minerals (3T+G) in our products. Please refer to our conflict minerals webpage for further details.
Motorola Mobility meets its material compliance obligations, including those laid down within the above legislation and expects its suppliers to meet their obligations, which include communicating substances of very high concern (under REACH), and full material disclosure in accordance with Motorola procurement policy.
Materials suppliers to Motorola Mobility are required to certify that products imported into the U.S. do not contain or are not manufactured with processes that use any Class I ozone- depleting chemicals (ODCs).
To learn about this process, please review our Supplier ODC certification form.
The W18 specification sets forth our materials disclosure requirements and acceptance criteria for items and materials used in the manufacture and delivery of products to our customers. We have taken a proactive approach and compiled a significant list of substances or substance groups targeted for exclusion, reduction or reporting. That list is divided into three sections:
The W18 specification and the Motorola Mobility Green Purchasing training presentation are available in Simplified Chinese:
Our Motorola Mobility Supplier Training contains Chinese translations within all key modules.
Suppliers can submit Material Declarations via any method that meets the IPC 1752A format, but we recommend the Motorola Mobility IPC Creator®. If requested, enable both "editing" and "content" the first time the file is used.
To streamline the W18 approval process, Motorola Mobility requires Material Declaration files to be submitted as XML files to the mailbox firstname.lastname@example.org.
Direct general W18 questions to email@example.com.
A PowerPoint presentation which provides a basic understanding of Compliance as well as an overview of preparing Material Declaration reports
The material includes the following:
See our FAQ (below).
Yes, selection of Accepted in the Motorola Mobility IPC Creator©, forms signifies a legal declaration.
It stands for Windchill Product Analytics, developed by Product Technology Corporation (PTC).
Currently Suppliers only receive email notification if there is an error in their XML file and it cannot be loaded. Additional notifications may be added in the future.
The weighted averaging approach is not preferred. First, any substances on the controlled list should be listed in worst case (highest value) among the two raw materials. Then, any substances on the reportable list should be listed in worst case (highest value). Next, adjust remaining non-reportable material of highest value downward as required to achieve measured part mass. This approach most correctly reports worst case for future use and avoids issues with possible noncompliance due to source raw material variations.
As it is difficult to disjoin and analyze coating and solder from other material, material suppliers should provide us with data on the solder paste or paint as received. But for such materials, the exact chemical composition of the components is different before and after spraying or print application and reflow manufacture. For coating where a carrier or solvent evaporates, you may have to measure thickness with a gauge or cross section and report the actual material left after processing. This may be the same as the percent of solids used in the paint industry. If paint reacts upon curing it should be the cured state that is reported. For solder paste, flux will be gone after reflow so report based on mass and composition of the metals in the alloy. Motorola is not looking for any greater detail than just finished part data, not part manufacturing process data.
Section 5.1.2 of the W18 specification requires the reporting of "all controlled and reportable substances with concentrations in excess of the reporting thresholds noted in Appendix A." For example, if the concentration of Chromium VI (Cr VI) compounds in one homogeneous material is 80 parts per million (ppm) and its reporting threshold in Appendix A is 100 ppm, then should the supplier enter "80 ppm"? Or, can they choose to not report the Cr VI since it is below the required reporting threshold? The supplier is not required to report any levels below the reporting thresholds in Appendix A. However, if you do report the data, it will not have any negative effect on the compliance decision.
In section 5.1.2 of the W18, it states, "Report all controlled and reportable substances with concentrations in excess of the reporting thresholds noted in Appendix A as contained within each homogeneous material." For instance, in one testing report, if the concentration of one substance is less than 2 ppm, it will be labeled as "not detected." How is the material disclosure made in this case? For example, if the presence of chlorofluorocarbons is listed as "not detected," can suppliers fill in the Material Declaration form with "chlorofluorocarbons: 0 ppm"? What if a spot test is done and a trace amount, such as 0.1 ppm, of chlorofluorocarbons is present? Will the supplier be penalized or found noncompliant? Motorola recommends that suppliers do not need to report not-detected substances if the detection limit is low. To date, the not-detected allowable limits have not been defined but technical guidance says that anything less than 10 ppm that is not intentionally added to the material does not have to be reported. A better interpretation of this definition is being discussed. In any case, suppliers should file all test results and document the test methods since these may later provide valuable details.
Reportable materials are much less critical because at this time there are not any known legal restrictions against their use. Motorola does not require a supplier to test for all substances on the reportable list at this time. Most parameters should be known by materials properties available to supplier and sub-suppliers and reported by engineering calculation.
X-ray fluorescence (XRF) testing is useful in screening for many elements, while engineering knowledge also can help to identify others. International Electrochemical Commission (IEC) standards eg: IEC62321 may be referenced to provide detailed guidance on further analytical testing.
A material safety data sheet (MSDS) obtained from a paint supplier indicates the presence of a restricted substance that exceeds Motorola's reporting threshold. The paint, prior to spray application onto a plastic substrate, contains 2.1 percent of Ethylene Glycol Monomethyl Ether and its acetate. This exceeds the Motorola reportable limit of 5 ppm. According to W18 specifications, process chemicals and other substances that do not remain with the part received by Motorola should not be included. Often, the solvents in paint evaporate during processing and no longer remain in the paint film. So, if the substances have completely evaporated from the coating during processing, these chemicals do not have to be reported to Motorola. However, if tests of the finished part show the restricted substance is still present in the coating in an amount at or above the reportable level for that chemical, then it should be reported.
When a Supplier Part Request is received from Motorola Mobility, there will be a specified due date in the request. Unless specified, the Material Declaration is due within two weeks.
When certified and exported, the W18 file is a legal document. Motorola relies upon the information provided by suppliers in order to ensure compliance with regulatory and voluntary commitments.
No. The Motorola Mobility WPASubmt@lenovo.com email box is fully automated. This is why it is so important to follow the naming conventions covered by the Motorola Mobility training material under the Submitting Material Declarations section. Actions do need to be taken if an email failure notice is provided by Motorola Mobility.
Yes. Up to 10 Material Declaration files can be submitted on one email in uncompressed format.
To submit more than 10 files on one email, they can be compressed to a Zip file. Note that all Zip files must end with the extension “zip” to be acceptable, and MUST have 1752 in the zip file name!
The largest single sized file is 5 MB. Note that XML files are substantially smaller than CXS files, and we have never seen a file close to this size.
Motorola Mobility recommends limiting the combined attachment size to 10MB. If the total of all attachments is larger than 10MB, please split them into more than one email.
Yes – the Motorola Mobility training material provides detailed information under the Submitting Material Declarations section. Remember, all files related to an email sent to WPASubmt@lenovo.com must have 1752 and either Home or MD in the title. Otherwise, the Material Declaration will not be loaded into WPA. Detailed information is available in the Motorola Mobility training material under Submitting Material Declarations.
Yes – the Motorola Mobility training material provides detailed information under the Submitting Material Declarations section. If a Zip file is related to an email sent to WPASubmt@lenovo.com, that Zip file must have 1752 in the file name. Detailed information is available in the Motorola Mobility training material under Submitting Material Declarations.
No. WPA will not accept a RAR file. The only file compression allowed is Zip format.
Yes – since the files related to the submission email sent to WPASubmt@lenovo.com must contain 1752 in the file name, files should be zipped prior to sending the email. Please ensure that the zip file contains 1752 in the file name.
The XML header(s) will be sent with the request email. If Suppliers elect to utilize the Motorola Mobility IPC Creator©, a click of a button will load all header information in the tool.
Material Declarations should be sent in XML format. The IPC creator output is an XML file, and should be submitted to the email address WPASubmt@lenovo.com.
No. The email can be sent from any address, but the Supplier Contact specified in the email address should be from the individual who completed the Material Declaration. This will allow Motorola Mobility to contact the appropriate person in case of any issues.
The WPA email (WPASubmt@lenovo.com) is automated and will only process XML files – all other attachments and text will be ignored. Supporting documentation (and any other correspondence) must be sent to firstname.lastname@example.org.
You can always contact the EDM team if you already are in contact with a team member. If not, send an email to email@example.com.
Yes. The latest version of the Creator tool is available for download.
MS Excel 2003, service pack 3 or later. It will work with MS Excel 2007 and 2010.
Yes, IPC-1752 class 5 or 6 are acceptable. In these cases the exemptions would be recognized but not valid for the system.
If already working with an EDM team member, they can be contacted directly. If not, send an email to firstname.lastname@example.org.
We are providing the Motorola Mobility CAS Number Tool to allow easy lookup by CAS# or Substance name. This tool can also be downloaded from the Material Disclosure website.
The Creator tool allows 12 digits after the decimal point. In addition, units of milligrams are available in the tool.
No, the supplier does not have enough information to do that. The IPC form must be signed by the original manufacturer.
No, just the subpart name, by whatever name the Supplier identifies it. Refer to subpart naming conventions for ODM products in the training material.
The training material on the Material Disclosure website provides both guidelines and detailed instruction on how to apply exemptions. These exemptions allow us to use Controlled Substances under very specific guidelines.
The Motorola Mobility specific W18 gets updated periodically driven by regulations, customer requirements, and “Green” initiatives.
The exemption that would apply in this case is 506 (Part contains Nickel and could have prolonged contact with skin but the manufacturer certifies it meets EN1811, per 76/769/ EEC and 94/27/EC), however, documentation of materials complying with the standard is needed.
If you know the material content, no lab tests are required. If not, lab tests need to include W18 substances analysis.
It is highly recommended, but is not required.
It is a rarely used disclosure type which requires Motorola Mobility business compliance team authorization to use.
Material should be homogenous (uniform), if the colorant is part of the material, then it is correct to declare it as a pigment in the material. But if the color is a layer, then it must be declared separately.
As the laser marking involves no material additions, you do not have to include it in declaration. You may be contacted by the EDM team for clarification.
All materials containing Nickel be evaluated for Nickel ion release per the Motorola 1202897W18 specification.
The system does allow usage of IMDS substances, but we do not recommend it.
An example of supporting doc is the MSDS. SGS reports would need to cover all W18 substances to be considered acceptable.
Test lab reports remain valid as long as there is no change in the composition of the materials being reported on.
A MISC IP Form, located on the Materials Disclosure website, is generally required. MSDS’s and similar documents may also be acceptable, pending Motorola Mobility approval.
Whenever a supplier cannot report a substance comprising over 10 percent of a material due to intellectual property concerns, a MISC IP form must be utilized. It is necessary to provide the original manufacturer name and supporting documentation which must assure compliance with W18. This can be through MSDS or IP form. The MISC IP Form is available on the Materials Disclosure website. The substance must be declared as Substance Name = "MISC., NOT TO DECLARE" and CAS# = "SYSTEM".
If the Supplier name is proprietary, a blackened out MSDS form may be acceptable, pending Motorola Mobility approval.
Materials declaration should only include what it is delivered to Motorola Mobility; therefore you’ll need to adjust percentages of substances in the list according to your manufacturing process. Typically, volatile substances are not part of the final part/ product delivered to Motorola Mobility. Volatile substances currently tracked by Motorola Mobility are identified in the Motorola Mobility CAS Tool.
Any Material containing >10% proprietary (undeclared) data requires a confirmation that no banned, controlled substances, or reportable substances are being used. Supporting documentation must be provided.