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How to Inquire Into Your Supply Chain

Given the above challenges in relying on SDS or test for information on PFAS, a significant source of information, and likely the main source of information, will have to be direct inquiry. The following are some recommendations for undertaking supply chain inquiries and controls for PFAS in the components you acquire to make your product.

1.  Have a list of all the components, substances, and mixtures, by part number, that go into making your product.

• Recall that ‘component’ simply means something you acquire that goes into the product you provide. A component might be a single, simple article, a complex assembly, an amount of adhesive, or paint that is applied to part of your product.
• Be aware of whether materials contribute to your product that are not listed in your bills of material (BoMs) – for example do assembly drawings call for adhesives, or stock hardware “as needed” in assembly drawing notes.
• Consider all related labels, manuals, cases, packaging, and shipping brackets/braces – they are part of the overall product you are supplying.
• Consider all relevant standard options and non-standard requests for the product.

2.  Sort your list of components into those for which you control the material and finish specifications (i.e., fabricated parts – FAB parts), and those for which you do not control the material and finish specification (i.e., Off the shelf parts – OTS parts).

• Carefully consider assemblies made for you by a contract manufacturer. In some cases, you might control the bill of materials completely, and in others your vendor might have some say in how components of the assembly are sourced.
• Carefully consider items that might be defined by special purchase agreement with a supplier – such as a custom variation on a standard power supply – these might contain a combination of your material requirements with their material requirements.
• Modify your lists as need in response to your ongoing design changes.

3. For OTS components, develop a survey process for your direct suppliers to gather and store required PFAS information.

• Your Enterprise Resource Planning (ERP) system might have an item master where you can collect information.
• There are many 3rd parties that offer supplier survey services and related databases that can provide quantity roll-up for bills of material.
• You can provide a link to this webpage as one aspect of the information you provide in your survey.
• Keep in mind that if you have different OEM sources for the same item, they could contain different types and different quantities of PFAS – be prepared to store their survey data separately, but account for the selection of one or another in your total product considerations. 
• Be very clear about some key concepts in your survey information, such as:
  • What “zero” content means  (for example, because of previous regulatory work, such as dealing with EU RoHS, some suppliers consider “less than 0.1%” to be the same a “zero content”).
  • The difference between “none present” and “none intentionally added”
  • The component’s manufacturing date range, or serial number range, for which the data is relevant.
  • Should your suppliers report only information they have received from their own supply chain, or should they actively survey their supply chain.
  • If threshold measurements are important, make sure the denominator for those measurements is clear. For example, you might have to explain the difference between the European REACH interpretation of article versus the EPA interpretation.
  • Packaging materials for components are also in scope of the inquiry – you might forward completely packaged component to your own customers or field service operations as replacement parts. 

4. For FAB components, you will most likely have to modify the materials and finish specifications in your drawings.

• If the component must be made from a fluoropolymer or fluoroelastomers (which are PFAS but might ultimately be allowed greater use in light of developing PFAs restriction laws) be sure to consider the possibility of process residues and additives in the material and specify accordingly. For example, “PVDF made without PFAS processing aides and additives”.
• Ensure that finish specifications are based on well-defined and well-understood materials and processes. Paints and other coatings can contain polymer and non-polymer PFAS.  
• While using a generic chemical description for the material or finish specification gives your supplier some flexibility, using a specific material trade name specification that you have fully investigated could give you greater control.
•  If your component fabrication drawing calls for some sort of marking, such as marking with your part number, be sure the ink is specified in line with your PFAS goals. Inks can contain polymer and non-polymer PFAS.
• If the fabricated component requires cleaning or similar processing, be very clear about what substances should be used in the process. Recall that PFAS concentrations of regulatory interest can be as low as several parts per billion. Even residual cleaning solutions on a small part could have a compliance impact.
  •  Try to avoid having fab drawings that call for additional parts (e.g., by means of notes on the drawing) in their construction. Use a bill of materials for such a structure. In any case, make sure the material and finish specification blocks clearly state all materials and finishes required to make the component.  

5.  You are likely a supplier to someone else, so also develop a PFAS profile for your products.

• Consider how variations in component source or component fabrication date might impact your product representation (for example, you might need to state a range of possible PFAS quantity in your output).
• Consider how standard options and NSRs will be represented.
• The packaging materials used for your product are also of concern and might have to be passed on by your customer to their customers or service operations (e.g., as a replacement part). List packaging materials in a separate group.  
• At a minimum, your downstream customers will likely have an interest in which PFAS is present in your product, where they are located in your product (described in terms of the EU interpretation of “article” and with enough information to locate the article within the product), and for what reason the PFAS is present in each article.

If possible, it will be very helpful to express any information you can about when certain uses of PFAS can be replaced with alternative substances or when the product as a whole will be PFAS free – or replaced by an equivalent PFAS free product. 

Supplier EHS/Compliance Staff

As you consider gather information from your supply chain, keep in mind that many companies do not have resources allocate for fairly complex regulatory issues such as PFAS reporting and restrictions, particularly in light of the variety seen in existing and pending legislation. This might be an aspect to bring into your supplier qualification process. Certainly invite all your suppliers to review this information page.

Please note:  SEMI makes no warranties or representation to the accuracy or usefulness of the information contained on this webpage. Accuracy is solely the responsibility of the user.  Users are cautioned to refer to other relevant literature of the subject matter herein.  This information is subject to change without notice. This "explainer" was developed by members of the SEMI PFAS Working Group. Please send suggestions for improvement to [email protected]