Compliance declarations, built from your BOM and your suppliers' own paperwork.

An OEM wants to know whether an assembly meets RoHS, which REACH Candidate List substances it holds, which smelters its conflict minerals passed through, or every substance in it as an XML file. The answer exists only in pieces: a BOM of a few hundred lines, and a folder of certificates, statements and spreadsheets from the makers of those parts, each written for its own part on its own date.

In the proof of concept, AI works through copies of requests you already answered and drafts the reply your quality lead would have signed, in the format the customer asked for, with the supplier document behind every line. Whatever it can't back with a document on file goes on the signer's list, never into the answer.

The request sets how deep the answer goes. IPC-1752A, the materials declaration management standard, defines four classes: A answers a query list, B states the material classes in a product, C sums substance categories for the whole product, and D lists every substance in every homogeneous material, which buyers call a full material declaration. Classes can be combined in one reply. Revision B, published in July 2020, mirrors submissions to SCIP, the ECHA database that has taken every article supplier's REACH Article 33(1) information since 5 January 2021, and Revision C is dated June 2026. The draft answers in the class asked, only as deep as your files go: a part backed by a yes-or-no statement can't fill a Class D line.

An assembly's answer is hundreds of small ones. Each BOM line is matched by manufacturer part number to that maker's declaration, with the date and the part number suffixes it covers. Some lines have nothing on file, some files are years old, and some contradict each other, such as a statement claiming no exemptions beside a certificate that lists one. IPC-1752A leaves out process chemicals unless they end up as part of the product, so what your line leaves on the board, such as solder, coating, adhesive and labels, belongs in the roll-up beside the parts and the bare board. Every gap is listed with the part, each assembly it reaches and the supplier contact your team holds.

Exemptions changed in 2025. IPC-1752A says plainly that it is not a compliance guide and leaves the use and expiry of exemptions to the requester and the supplier. Delegated directives the Commission adopted on 8 September 2025 rewrite several RoHS Annex III entries from 1 July 2026. Entry 7(a), lead in high melting temperature solders, now expires on 30 June 2027 and was split into seven narrower entries, 7(a)-I to 7(a)-VII, that run to 31 December 2027. Entry 7(c)-I, lead in glass or ceramic other than capacitor dielectrics, expires on 30 June 2027 and 7(c)-II on 31 December 2027. A renewal application is due at least 18 months before an exemption expires, and the exemption holds until the Commission decides. Medical devices and monitoring and control instruments have their own list, Annex IV. The draft shows each exemption a supplier claims beside its current entry and expiry, and marks wording that has since been replaced.

The minerals templates moved too. The Responsible Minerals Initiative's Extended Minerals Reporting Template now covers cobalt, copper, natural graphite, lithium, natural mica and nickel, four of them added in version 2.0 in April 2025, and its Additional Minerals Reporting Template takes up to ten other minerals the user names. New CMRT and EMRT versions with functional changes came out on April 17, 2026. The RMI sets no reporting expectations and collects no completed templates, so each customer decides which version it accepts. A template is declared for the whole company, a list of products or a scope the supplier writes in. The draft merges the smelter lists from your suppliers' templates into the one your customer asked for, flags supplier files on an older version than that customer accepts, and leaves the choice of scope to your signer.

Your reviewer. The owner names the person who knows your declarations best, usually the quality or compliance lead who signs them. They hold each draft against the reply your team sent: parts matched, gaps found, exemptions read correctly, smelters carried over and questions sent back to the OEM. Include one request your team answered in full, one it could answer only in part, and one that asked for an IPC-1752A XML file.

After a yes, each new customer request gets a draft declaration and a gap list as it arrives, for about 30 days.

Your quality lead checks every line, chases the gaps with suppliers and signs or holds each reply, then sends it the way your team always has. Scoring runs through the month on the terms the test used.