Why is IBM requesting part numbers manufactured from several years back?
IBM is going through a PCD refresh for 3 year-old parts that are still in production but have not had an updated PCD. It is created to have you update the necessary information that may have changed due to product alteration, process change, other information that have not been provided before, new PCD version, etc. Also, there are several items here which were not present in the previous PCD version you have submitted and we need you to input them. From time to time, a re-submission of PCD is also expected to update exemption claimed that may have expired.
What is full material disclosure or FMD?
Full declaration of material composition of a product or a part, including the part weight and the substances present in the product/part.
Can a full material declaration (IPC 1752A) be submitted in lieu of providing PCDs?
No. The PCD form is the primary document that needs to be submitted to IBM. The FMD IPC 1752A can be submitted as a supporting document.
When a new Product Content Declaration is released by IBM, should the supplier review all tabs as they pertain to delivered product or only those tabs that have changed?
It is the supplier responsibility to understand the new changes that are integrated into Engineering Specification 46G3772 and the Product Content Declaration and ensure that deliverables are compliant and an updated PCD is submitted.
Should the PCD form previously provided to IBM be changed to the new form?
If changes to your declaration have occurred as a result of the updates in the PCD form, then it is your responsibility as IBM's supplier to submit an updated PCD. If no changes have occurred, there is no need to update pre-existing PCD.
What is an IBM EC Number and what it is used for?
The Engineering Change Number (ECN) is a unique number assigned when a set of product is released. It is used to record and track design changes throughout the prototyping and life-cycle phases of a product. A complete ECN is a 12 character field with the following:
|1 - 5
||10000 (is usually omitted and should bot be required in the PCD)
|6 - 10
||All alphabetic characters except B, I, O, Q, S, and Z are valid, and all numeric characters are valid
||Any alphabetic characters should be upper case but allow lower case as well.
How can we identify IBM EC Number?
EC Number is required to be filled in on the PN tab for MECHANICALS and ECAT. Please contact your IBM Procurement Engineer for any questions on PN EC level.
What is the accepted IBM Part Number format?
Valid format of IBM PN should not contain special characters such as hyphens or asterisk. IBM PN is consists of either a minimum of 7 characters or maximum of 12 characters. -00 first 2 fields, -000 next 3 fields, fields 6 to 7 are numeric, 8 to 9 are alphanumeric and 10 to 12 fields are numeric. EX:00A1234, 12A1234, 00AB123
Multiple IBM PNs are covered in this request; however, their declaration is not identical with each other. How do I create a PCD for all PNs?
If IBM requested multiple parts, suppliers are only allowed to consolidate multiple PNs in a single PCD if declarations are identical for which the answer set applies. This particular work around in PCD completion is stated in the “Scope and Instructions”.
What is an article?, i.e. supply connectors. For example, contact and shell.
ECHA guidance document is expected in 1Q2017 for clarification. Please consult your legal. Per the current PCD, In reporting a potential SVHC, you have to consider and report the weight of the smallest component (article) in the deliverable and where it can be found as per your legal.
If the substance is consumed(evaporates) during production andis not present in the finished article, does it have to be reported?
If the substance is used in the manufacturing process and not present in the article there is no requirement to be reported in the PCD
When is a deliverable considered as a Vendor Logo Product?
Vendor Logo Product (VLP) is a requirement for the whole machine. This applies to deliverables which have a logo or brand other than IBM and are not included inside an IBM branded product. Only final assemblies (Top Assy) in any form factor including standalone could be declared as VLP. For this instance, we need to establish if these parts are finished VLPs. There are examples listed in that section of the PCD which you can check for reference.
Our product contains prohibited substance thus we have answered Yes to Question 2. Will our product be marked as non-compliant?
This response will not allow PCD to autoload. If this declaration is correct, then PCD is non-compliant as per the latest release of Engineering Spec.
46G3772 of IBM and will require you to contact your IBM procurement representative. Refer to Table 1 in 46G3772 for the details of restrictions.
This may not be the case always. Many substances are not completely prohibited and may have a specific allowed application. One example is Cadmium.
All Cadmium used in plating or on a surface coating is prohibited. In the RoHS requirements, Cadmium alloys and compounds used in electrical contacts for the purpose of
reliability are allowed if the RoHS exemption 8b is claimed. IBM intends to remove exemption 8b where possible from all products.
My part used a grayed out exemption in the PCD but it is still valid and renewed by my company. How do I claim this exemption?
Expired (grayed out) exemptions are not acceptable and cannot be used in IBM products. Suppliers need to contact the IBM Procurement engineer responsible for the part.
My PCD is for Lead Acid battery, which is not included in the scope of RoHS. How do I report the Lead contents?
For Lead in applications not regulated by RoHS, report Lead contents in the Reportable tab, Row 209. There is a specific chemical category for Lead Acid batteries.
I cannot access the links provided on the packaging tab of the new PCD version. What can I do to resolve this?
If you find issues with the links in the PCD Microsoft Excel document and see either a spinning icon or receive the following error message, try opening the links in a different internet browser.
How do we know supplier packing materials are delivered to customer?
If IBM has not specifically instructed whether or not the MT/Mod/PN is customer orderable, it should be assumed as such and an ESI Pkg data form should be submitted. Any questions should be directed to IBM procurement.
If the supplier sends a wood pallet with product and IBM uses the same wood pallet, do supplier need to fill up Packaging tab?
If the pallet will be used by IBM to ship product to Customers then Yes. The Supplier needs to include/report all packaging materials data used to ship products
What is in the ESI Packaging link? Does it need to be completed in parallel with the PCD?
The ESI Packaging link contains information to help the supplier assess, review and register their product packaging. The need to complete the ESI Packaging link does not inhibit the completion or submission of the PCD.
Are cable assemblies considered "finished products" (i.e. stand alone, final assemblies in any form factor)?
Cable assemblies for IBM products are considered components of the product, not finished products.
If the product label is too small for all of the symbols and verbiage, what does a supplier need to do?
When the product is too small to contain all of the labels required, there generally is an allowance in the law or standard for this situation, such as a label on the packaging. IBM's specification 46G3772 contains details of where a label can be located if the device is too small.
Is there any difference between prohibited and RoHS substances?
In 46G3772 and on the PCD, there are two different tables, one for prohibited and one for RoHS substances. The RoHS substances are also prohibited at a designated level but have several allowable exemptions which is why they are listed on a table separate from the prohibited.
Some of the substance categories in the PCD do not have CAS numbers associated with them, such as the brominated and chlorinated flame retardants. Where can I find a list of CAS numbers applicable to those substance groups?
If a government authority has cited a web site with relevant CAS numbers, then that web site is cited in 46G3772. For example, for these substances, a web site with a listing of CAS numbers are provided:
Perfluorooctane sulfonates (PFOS) and salts, C8F17SO2X (X=OH, metal salt, halide, amide and other derivatives including polymers), or Compounds that contain C8F17SO2, C8F17SO3 or C8F17SO2N, (for a list of PFOS CAS numbers see OECD Annex 1 at http://search.oecd.org/officialdocuments/displaydocumentpdf/?cote=env/jm/mono%282006%2915&doclanguage=en)
Perfluorooctanoic acid (PFOA CAS 335-67-1) including its salts and any other substance having linear or branched perfluoroheptyl derivatives with the formula C7F15- as a structural element, including its salts except those derivatives with the formula C7F15-X, where X= F, Cl, Br and any other substance having linear or
branched perfluorooctyl derivatives with the formula C8F17- as a structural element, including its salts, except those derivatives with the formula C8F17-X, where X= F, Cl, Br or, C8F17-SO2X', C8F17-C(=O)OH or C8F17-CF2-X' (where X'=any group, including salts) (Annex Z and for a more extensive list of PFOA CAS numbers see OECD Annex 3 at
Perfluoro carboxylic acid and related compounds (PFCAs) for a list of PFCA CAS numbers see OECD Annex 4 at http://search.oecd.org/officialdocuments/displaydocumentpdf/?cote=env/jm/mono%282006%2915&doclanguage=en
Perfluoroalkyl sulfonates (PFASs) (for a list of PFAS CAS numbers see OECD Annex 2 at http://search.oecd.org/officialdocuments/displaydocumentpdf/?cote=env/jm/mono%282006%2915&doclanguage=en
There is not such a web site for the brominated and chlorinated flame retardants. Annex X in 46G3772 lists out some common brominated flame retardants with the respective CAS number.
If a complex product contains a RoHS substance (eg: lead) at multiple locations in the assembly, how do suppliers correctly declare the location of the RoHS substance declared when the number of rows in the PCD is limited?
Questions tab of the PCD, and for the RoHS tab IBM will allow generalization of the declaration by exemption. For example: Pb in glass in 40 resistors, 5 devices with high lead content solder die attach, 4 flipchip devices with Pb flipchip bumps, 3 devices with Pb in the sealing glass.
Does IBM have any plans for removal 7C-I exemption due to its impending expiry on July 2016?
IBM is expecting 7C-I to be extended with a changed scope (some applications could expire and others could be assigned new sub-exemptions), 3 devices with Pb-ed sealing glass
If REACH SVHCs exceed 0.1% during process but less than 0.1% in articles, does the supplier need to report them to IBM?
The use of chemicals in manufacturing is covered on REACH rules when the manufacturing occurs in a REACH controlled region. Outside the EEA, the rules of the country of origin apply. For reporting SVHC’s in Articles, the threshold is 0.1% w/w of the SVHC which remains in the final component article.
Does IBM have an interpretation of what is considered an article based on the new ruling?
We expect updated guidance from ECHA will shine a light on the matter. Currently IBM cannot be certain how deep into each article the guidance will go. At this time we believe that individual components will be considered articles (examples: resistor, capacitor, diodes) and expect that 'once an article, always an article' is a good start. However, it is up to the supplier to make the final determination based on the legal standards and guidance.
Does the current PCD form contain the means for the supplier to report SVHC greater than 0.1% w/w of components that make up the part number being reported on the Part Numbers tab?
IBM is working on the next PCD release that will be available in late July 2016; this PCD will have an updated SVHC tab that will allow supplier to report SVHC greater than 0.1% w/w of components that make up the part number being reported on the Part Numbers tab. As always, there is a 60 day transition period where the existing current PCD version is accepted.
How does the ECJ ruling affect packaging/shipping materials, can you give examples?
Examples Include: foam packaging materials, plastic trays or bags, descicant bags or other forms of humidity control, adhesives used in tapes, and tape.
If our downstream supplier refuses to provide product or user-defined CMRT, what are the next steps we can take to meet IBM’s requirements?
Product level reporting keeps the smelter list restricted to only smelters providing materials into IBM products. This helps to ensure that IBM's CMRT to our customers and our SEC filed report are accurate. Product level reporting also reduces the number of unsolved smelters in a particular CMRT which translates to fewer smelters requiring removal. You might exercise commercial leverage on the supplier to drive the requirement and understand the reason why they refuse. If still unsuccessful, you may provide the supplier names to IBM. If they are also a direct supplier to IBM we may be able to gain their cooperation.
What is the purpose of the new revision of CMRT that is releasing at the end of April? What new additions or changes can we expect?
The major changes you will see in CMRT 4.10 (released April 29, 2016) include:
• Corrections to all bugs and errors
• Enhancements which do not conflict with IPC-1755 •Additions and clarifications in the instructions and definitions
• Smelter List Tab: Re-introduction of “smelter not yet identified”
• Smelter List Tab: Inclusion of drop down menu for smelter ID that triggers auto-population of columns B to J
• Translation improvements and addition of Turkish language
• Updates to the Smelter Reference List and Standard Smelter List as of March 23, 2016
• Updated lists and corrections
• ASCII character set alignment
For purposes of filling out a CMRT, suppliers are expected to survey all their upstream suppliers. Why is there a need to survey non-3TG suppliers?
It is important to verify that there have been no changes to 3TG content. Non-3TG suppliers may have made that determination previously without having all required information from their respective suppliers.
When should we submit the latest EICC CMRT 4.10?
4.01b and 4.10 are both acceptable for the interim CMRT. Due date was May 1. The November 2016 CMRT must be 4.10
If these Question 5 in the CMRT is answered "No", does IBM expect the supplier to pursue the response with their downstream suppliers who submitted the CMRT?
You need to exercise commercial leverage on the supplier to drive the requirement and challenge why they cannot achieve 100% in-scope supplier participation.
Is the Helpdesk support available all the time?
Yes, ticketing and callback are available 24/7, but the live chat feature is only available during normal business hours for the Manila WSP team 6 am to 6 pm Asia Pacific Time (SGT) UTC+8.
We do not build this part but we bought from another vendor. Do we still need to submit the PCD?
Supplier is responsible for the PCDs for any parts that that are local sourced. If supplier does the sourcing, IBM does not have the contacts to request the PCDs from their suppliers. Therefore supplier needs to obtain the PCDs for these parts.
What is an ECAT?
ECAT is Electronic Card Assembly and Test. It is a compilation of various electronic components that when integrated on a printed circuit card makes a sub assembly which performs specific functions in a higher level assembly or finished product. The functionality may include logic, memory and features.
When will the supplier upload tool go live?
October 3, 2014
When will this requirement start?
October 15, 2014; note that the initial phase only covers selected part numbers and excludes Microelectronics (Semiconductor) and Component supplier part numbers.
Will WSP use full material disclosure to validate PCD content?
Yes, any document that was used to fill out the PCD should be provided, including but not limited to Full Material Disclosures (FMD), test result reports, prints, engineering drawings, certificates of compliance (CoC) and Material Safety Data Sheets (MSDS/SDS). WSP will use the documents provided to validate the PCD content.
How will I get a copy of the training material and the user manual for the supplier upload tool?
The presentation was emailed to each attendee after the training sessions; check your spam folder if you did not receive it; also you may access the presentation materials at the Supplier portal site: http://pcd-supplier-support.com/index
under the “Event Playback” tab.
What should I do if I haven’t gotten approval notification for my registration?
Check your spam folder; if you still don't see the approval notification, follow-up with the contacts listed here: http://pcd-supplier-support.com/index
under the “Contacts” tab.
Will the contact information page be made available?
Contacts can be found on this site: http://pcd-supplier-support.com/index
under “Contacts” tab. You may also work directly with your IBM procurement representative.
Is this requirement for US locations or just Europe locations?
This is a global requirement.
How do we decide what documents to upload other than MSDS?
Only documents that support the data you have declared in the PCD should be uploaded to the supplier portal.
Is this IBM requirement that starts on Oct 15th just for new orders or for products already shipped?
If you receive a PCD request and are asked to provide technical documentation along with your completed PCD, then please accommodate the request.
Can more than one person register per company to upload files?
How is confidentiality preserved?
IBM has a NDA in place with WSP. WSP ensures that all documents submitted are treated as highly confidential. If a company-specific NDA is needed, send your company form to WSP for completion.
If we have an independent lab evaluating our product for CE marking (which now includes RoHS2), why duplicate all the documents through the IBM portal? It will already be certified.
For the PCD documentation upload requirement, IBM is not asking for the complete technical files in support of CE Marking i.e. safety, emissions, RoHS,... rather IBM is requesting only documents that validate the content of the PCD so that IBM can ultimately generate IBM's technical file to meet EN50581. IBM may have to request additional technical documentation or other information if or when IBM is audited by a government authority.
Can you review the email we need to send after the submission of materials is complete?
You don't need to send WSP an email after a submission. The system will automatically notify the supplier and WSP that a submission was made on the supplier portal.
For MSDS, are we referring to the MSDS for each homogenous material or the final product?
Are there any specific requirements for technical documents? For example for FMD, we didn't provide detailed data as per IPC 1752?
Only documents that support the data you have declared in the PCD should be uploaded to the supplier portal. Technical documents should be converted to pdf file format before uploading to the system.
WSP is IBM's 3rd party service provider for PCD processing. WSP's Supplier portal is separate and distinct from the link provided above.