Compliance Responsibilities for Suppliers Using Only Customer-Approved Materials

Q: As a supplier, if I’m required to buy only customer-approved materials, am I responsible for ensuring compliance with restricted/declarable substances, or is my customer?

A: In many cases, the materials have been evaluated for performance and quality without taking chemical composition into consideration. As such, the chemical composition may be unknown. If you are commercially responsible for purchasing the materials, the respective supplier(s) of the materials will be duty bound and/or contractually bound to support your substance information request. In addition, there may be multiple materials qualified for use, but you as the supplier may choose which ones to use. In this instance, you control the substance composition of the product in question.


This content is accurate as of June 7, 2019.

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