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W18 Reporting FAQs
FAQ Pertaining to the W18 Reporting Document
- If raw materials of a part are sourced from two suppliers but with measurable differences, how should the material disclosure be made?
- What is the best way to analyze and report a coating film or solder on components?
- If the concentration of one controlled or reportable substance is below the W18 reporting threshold, do suppliers need to report that data?
- If the concentration of a substance is extremely low or can be labeled as "not detected," how should material disclosure be made?
- Are engineering calculations accurate enough for reportable materials testing?
- If an X-ray test returns a "Not detected" result, do suppliers need to use a more accurate method to get an exact concentration?
- Should the presence of a restricted substance in paint (prior to processing) from a supplier be reported on the W18?
- How long do suppliers have to complete W18 compliance and 1752A e-form requests?
- For each sector within Motorola, typically who is in charge of the W18 compliance process?
- Is the information provided by suppliers in the W18 legally binding?
- Does the new reporting process only apply to Motorola Mobility?
- Will all Motorola sites be switching to the XML form?
- If we supply the same part to both Mobile Devices & Home, should report it to both?
- Will there be a transition period when Suppliers can use either XML or AIAG Compliance Connect CXS formats, or will there be a hard cut over date?
- We receive requests from both Motorola groups. How do I tell which group a particular part is for? Will this be noted in the email request?
- Is the new process basically the same?
- Is this declaration legally binding?
- What does WPA stand for?
- Will there be different form submittals for Land Mobile Products, Infrastructure and Mobility? Is this rollout only for Mobility Products?
- What kind of email notifications will I receive from Motorola Mobility?
Questions Concerning File Submissions
- Do we have to resubmit data previously submitted as a CXS file?
- Do Suppliers have to do anything after emailing file submissions?
- Is there a limit to the number of files that can be submitted on one email?
- How can I submit more than 10 files at once on one email?
- What is the largest file size for a Material Declaration that can be accepted by WPA?
- What is the largest file size I can send to the Supporting Materials email addresses?
- Is there a special naming convention for XML file submissions?
- Is there a special naming convention for Zip file submissions?
- What compressed formats are acceptable to WPA? Can I submit a RAR file?
- My email client automatically zips file attachments. Is there anything special we should do?
- How will Suppliers receive XML headers?
- Should Suppliers send an XML or PDF file?
- Must the XML file sent to WPASubmittal@motorola.com be from the supplier contact email address?
- Where should Suppliers send supporting documentation (ie: any correspondence other than XML Material Declaration XML files)?
- Whom should Suppliers contact with issues/problems/errors?
- Can Suppliers still submit Material Declaration submission via MCMS?
- Is Print Acceptance Form (PAF) still in place in MCMS?
Questions Concerning the new Form
- Is the Motorola Mobility IPC Creator© available free of charge to Suppliers?
- What are Microsoft Excel requirements for the Motorola Mobility IPC Creator©? Will it work for MS Excel 2007/2010?
- Are IPC-1752 Class 6 forms acceptable as long as exemptions are not needed?
- If a Supplier has questions regarding how to to properly fill-out the XML form, who should be contacted for assistance?
- Does the new XML file have the same capability to check our declared numbers in the worksheet like the .CXS did?
- Why doesn't Motorola assign Part Usage, since that information is in the header sent from Motorola?
- Can the Motorola Mobility IPC Creator© list all CAS numbers like the current AIAG Compliance Connect does? Can this feature be added?
- How many digits will the Motorola Mobility IPC Creator© form allow? For example, if an ink is only .000001 grams, will the form allow values this small? If there are two ingredients in the ink they would be .0000005 g each
- Can a Supplier sign this IPC form on behalf of an homogeneous supplier?
- Is Motorola Mobility requesting the Vendors name and part number for subparts?
- What are all these exemption numbers? We have not seen anything like this previously. What laws/regulations require the use of these exemptions?
- Will the W18 substances be updated on a regular schedule or as regulations change? Is it possible for Suppliers to proactively anticipate when new substances may be added?
- Does W18 Exemption 501 (Part contains Nickel, but will not have prolonged contact with skin) apply to side keys?
Questions Concerning Compliance
- Do I understand that CoA (lab tests) are needed for every chemical in a material? Not just the RoHS 6?
- Is ISO14001 a requirement?
- What is a Class-A non homogeneous disclosure?
- Must Suppliers mechanically disjoint color?
- What if the product is laser marked? How would we report that?
- Is a phone charger a home or mobile device?
- Is NiPdAu plating on part terminal exempted?
- Will Motorola Mobility allow the use of Basic substances such as Acrylic Resin or Epoxy Resin where there is a mixture and no CAS numbers apply to a Basic Substance?
- For non-listed substances, what would be considered supporting information? Would SGS report be acceptable?
- Do lab reports have an expiration date? How long are lab test reports valid?
- What supporting information is needed for a MISC substance, which comprises over 10% of the material content? Does Motorola have a standard format?
- If there is a trade secret ingredient comprising more than 10% of a material, what does Motorola Mobility require? If a Supplier's name is proprietary, must they still fill-in the MISC IP form?
- How is volatile material >10% handled?
- How do I handle >30 % proprietary materials?
If raw materials of a part are sourced from two suppliers but with measurable differences, how should the material disclosure be made?
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. A specific example of how to analyze coatings is located in:
If the concentration of one controlled or reportable substance is below the W18 reporting threshold, do suppliers need to report that 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" in the Automotive Industry Action Group (AIAG) form? 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.
If the concentration of a substance is extremely low or can be labeled as "not detected," how should material disclosure be made?
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.
If an X-ray test returns a "not detected" result, do suppliers need to use a more accurate method to get an exact concentration?
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.
Should the presence of a restricted substance in paint (prior to processing) from a supplier be reported on the W18?
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 and the Compliance Connect report, 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.
At Motorola, the Environmental Data Management team is typically responsible for getting the W18 data and IPC 1752A form; and making sure their products are compliant.
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.
Yes. Any information provided by Motorola Mobility applies only to Motorola Mobility. Motorola Solutions may move to another format as well, but the suppliers should contact them directly as they are a separate company
All Motorola Mobility sites will move to XML format for materials declarations. Motorola Mobility is comprised of the Home and MD (Mobile Devices) businesses.
Material declarations criteria is the same for both businesses
No. If a Supplier provides the same part to both businesses, it only needs to be declared once
Will there be a transition period when Suppliers can use either XML or AIAG Compliance Connect CXS formats, or will there be a hard cut over date?
We are asking our suppliers to begin submitting XML files as soon as the official notification is sent. While there will be a grace period during December 2011, Suppliers should understand CXS file submission will take longer to process as a special request. AIAG Compliance connect will not be supported by Motorola after 2011
We receive requests from both Motorola groups. How do I tell which group a particular part is for? Will this be noted in the email request?
After loading the XML header into the Motorola Mobility IPC Creator©, the business is indicated in the Requestor Information section of the form, located in the upper left corner:
“Motorola Mobility” is displayed as requestor for MD, “Motorola Mobility- Home” is displayed for Home parts
The required information is basically the same; however we now require suppliers to add exemptions in the submission form
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)
Will there be different form submittals for Land Mobile Products, Infrastructure and Mobility? Is this rollout only for Mobility Products?
This rollout is only for Motorola Mobility
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
No, data will be migrated from the legacy Electronic Material and Aggregation Reporting System (EMARS) to WPA, there is no need to resubmit the data (unless changes in materials have been made)
No. The Motorola Mobility WPASubmittal@motorola.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
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 10mg. If the total of all attachments is larger than 10mg, 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 WPASubmittal@motorola.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 WPASubmittal@motorola.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. 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!
Yes – since the files related to the submission email sent to WPASubmittal@motorola.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 WPASubmittal@motorola.com
Must the XML file sent to WPASubmittal@motorola.com be from the supplier contact email address?
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
Where should Suppliers send supporting documentation (ie: any correspondence other than XML Material Declaration XML files)?
The WPA email (WPASubmittal@motorola.com) is automated and will only processes XML files – all other attachments and text will be ignored. Supporting documentation (and any other correspondence) must be sent to the appropriate business email address:
No. The MCMS MRT portal will no longer be available for submission. Suppliers simply need to email their completed XML file to WPAsubmittal@motorola.com
PAF is still in place, it is a component engineering tool. If any change is implemented, Suppliers will receive notification
Yes. Suppliers who attended webinars received the early version in their attendance confirmation. The latest version of the Creator tool will be available for download on our Material Disclosure website
What are Microsoft Excel requirements for the Motorola Mobility IPC Creator©? Will it work for MS Excel 2007/2010?
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 a Supplier has questions regarding how to properly fill-out the XML form, who should be contacted for assistance?
Does the new XML file have the same capability to check our declared numbers in the worksheet like the .CXS did?
When the Motorola Mobility IPC Creator© is saved, automated error checking is performed. An explanation of the error codes is contained in the training material. It is strongly recommended not to rename XML files to avoid delays in processing or potential non-receipt of files
In preparation of go-live, the Motorola Mobility IPC Creator© has had the code locked down. We will consider this enhancement for future versions of the tool
Can the Motorola Mobility IPC Creator© list all CAS numbers like the current AIAG Compliance Connect does? Can this feature be added?
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
How many digits will the Motorola Mobility IPC Creator© form allow? For example, if an ink is only .000001 grams, will the form allow values this small? If there are two ingredients in the ink they would be .0000005 g each
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
What are all these exemption numbers? We have not seen anything like this previously. What laws/regulations require the use of these exemptions?
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
Will the W18 substances be updated on a regular schedule or as regulations change? Is it possible for Suppliers to proactively anticipate when new substances may be added?
The Motorola Mobility specific W18 gets updated periodically driven by regulations, customer requirements, and “Green” initiatives
Does W18 Exemption 501 (Part contains Nickel, but will not have prolonged contact with skin) apply to side keys?
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
Do I understand that CoA (lab tests) are needed for every chemical in a material? Not just the RoHS 6?
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
If it is specifically a phone charger, it is a Mobile Devices part. When you get the request, it will be indicated “Motorola Mobility” as requestor for MD and “Motorola Mobility- Home” for Home parts
All materials containing Nickel be evaluated for Nickel ion release per the Motorola 1202897W18 specification
Will Motorola Mobility allow the use of Basic substances such as Acrylic Resin or Epoxy Resin where there is a mixture and no CAS numbers apply to a Basic Substance?
The system does allow usage of IMDS substances, but we do not recommend it
For non-listed substances, what would be considered supporting information? Would SGS report be acceptable?
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
What supporting information is needed for a MISC substance, which comprises over 10% of the material content? Does Motorola have a standard format?
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
If there is a trade secret ingredient comprising more than 10% of a material, what does Motorola Mobility require? If a Supplier's name is proprietary, must they still fill-in the MISC IP form?
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