Substance rollups that refuse to guess
A compliance rollup is only as good as its worst line. The interesting engineering is not the arithmetic — it is what the system does about the part whose supplier has never sent a declaration.
What it is, and what it is not
A traversal from a product through its resolved structure to parts, from parts to materials, and from materials to the substances they contain — with a supplier declaration as the evidence behind each leaf, and a status that reflects the weakest link rather than the average.
It is not a certificate generator. It will produce the evidence pack behind a declaration of conformity, but the declaration is a legal statement made by a person in your organisation, and a system that produced one automatically would be manufacturing liability rather than compliance.
It is also not a substance database. Manufacturing PLM holds the regulations you care about, the substances they restrict and the thresholds that apply; the actual composition data comes from your suppliers, dated and attributable, because that is the only version of it that survives an enquiry.
The mechanism: an unknown is not a zero
This is the whole page. When a part has no supplier declaration, the honest rollup result is *unknown*, and unknown propagates upward to make the product uncertifiable.
The tempting alternative — treat missing data as zero, roll up the parts you do have evidence for, and report a number under the threshold — produces a green product status that is not false in any single field and is completely wrong as a conclusion. It is also the behaviour most spreadsheets have, because a blank cell sums as nothing.
So the rollup reports three states rather than two: compliant with evidence, non-compliant with evidence, and insufficient evidence. The third is the useful one, because it converts a vague sense that the data is patchy into a finite list of parts and suppliers to chase.
Thresholds are per regulation and per substance, and homogeneous-material thresholds are applied at the material level rather than the part level — which is what RoHS actually requires and what a part-level percentage quietly gets wrong.
The failure it prevents
A customer asks for a RoHS declaration. Somebody exports the BOM, cross-references a folder of supplier certificates, finds most of them, and issues the declaration.
Two of the certificates were for a different revision of the part. One supplier changed their sub-tier source eighteen months ago and the certificate on file predates it. Four parts had no certificate at all and were assumed compliant because they are metal fasteners.
The declaration is signed and is probably fine. But nobody can reconstruct which evidence supported it, and when the enquiry comes — from a customer, an authority, or an acquirer's diligence — the answer takes three weeks and the confidence at the end is low. Evidence attached to the part at its revision, with a date on every declaration, makes that reconstruction a query.
How it meets the rest of the product
Rollups run over resolved structures, so compliance is answered for a configuration: this product, as at this date, for this variant, at this plant. A part present only in a superseded revision does not affect the status of what ships today, and a variant you do not sell into the EU is not dragged into an EU assessment.
Because the rollup shares the resolver with cost, mass and where-used, the lines it counted are the lines the other rollups counted. A compliance number that disagrees with the cost rollup about what is in the product is the kind of inconsistency nobody finds until it matters.
Declarations and certificates are documents in the vault with revisions and expiry, so a certificate that lapses raises the products depending on it rather than sitting quietly in a folder. Supplier change notifications tie in: a supplier changing a sub-tier source invalidates the declaration that predates it.
The Compliance Agent works this surface at the tier you set — chasing missing declarations, summarising what changed since the last assessment, and drafting the evidence pack. Every claim cites the declaration and the revision it applies to.
How it meets your ERP
Compliance status is engineering data and masters here, but the parts it concerns are the ones your ERP transacts, so the two need to agree about identity. Matching runs on manufacturer part number first and internal number second, the same as everywhere else, and unmatched items are surfaced rather than assumed.
Where a product is blocked as uncertifiable, that is visible against the parts your ERP holds — including on-hand quantity and open purchase orders, so the conversation about whether to keep buying a part with no declaration happens with the numbers present.
Nothing is written back. Manufacturing PLM does not set an ERP item flag, block a purchase order or place a hold. It produces the status and the evidence; if you want a purchasing block, that rule lives in your ERP and reads what Manufacturing PLM published.
Where the boundary is
Manufacturing PLM does not maintain regulatory content. The substances, thresholds and scopes for RoHS, REACH, WEEE, conflict minerals and Proposition 65 are configured, and keeping them current as regulations change is a subscription or a job somebody owns — not something the product silently keeps accurate on your behalf.
Full-substance disclosure and sustainability footprinting are not this. Rolling up a declared substance list is a different problem from a life-cycle assessment, and a product that conflated them would be doing neither honestly. Sustainability rollups follow the same structural path and are a later capability.
Facts
| Path | Product → resolved lines → material → substance |
| Evidence | Supplier declarations, dated and attributable |
| Missing data | Unknown, never zero — it blocks certification |
| States | Compliant · non-compliant · insufficient evidence |
| Thresholds | Applied at homogeneous-material level, per regulation |
| Scope | Per configuration — date, variant and plant |
| Certificates | Vault documents with revisions and expiry |
| Not offered | Auto-issued declarations · regulatory content · LCA |
Frequently asked
What happens when a supplier declaration is missing?
The line rolls up as unknown, and unknown propagates to make the product uncertifiable. Treating a blank as zero produces a green status that is not false in any single field and completely wrong as a conclusion — which is exactly what a spreadsheet does.
Will it generate our declaration of conformity?
It produces the evidence pack behind one. The declaration itself is a legal statement made by a person in your organisation, and a system that issued one automatically would be manufacturing liability rather than managing compliance. The evidence is the part worth automating.
Are thresholds applied per part or per material?
Per homogeneous material, which is what RoHS actually requires. A part-level percentage quietly understates concentration in a small homogeneous component, and it is the kind of error that passes review because the arithmetic is correct and the basis is wrong.
Does it know which products are affected by a change?
Yes, through resolved structures — so it answers for a specific configuration: this product, as at this date, for this variant, at this plant. A part present only in a superseded revision does not affect the status of what actually ships today.
What about certificates that expire?
They are vault documents with revisions and expiry, so a lapsing certificate raises the products depending on it rather than sitting in a folder. A supplier changing a sub-tier source also invalidates any declaration predating the change, through supplier change notifications.
Do you keep the regulations up to date?
No. Substances, thresholds and scopes are configured, and keeping them current as regulations change is a subscription or a job somebody owns. A product that implied it silently maintained regulatory accuracy for you would be making a promise it cannot keep.
Is this the same as sustainability reporting?
No, and conflating them would mean doing neither honestly. Rolling up a declared substance list is a different problem from a life-cycle assessment. Sustainability rollups follow the same structural path through resolved BOMs and are a later capability rather than this one.