Closing Data Gaps in Compliance: Solving the Last-Mile Problem

You’ve built a compliance program. You’ve engaged your suppliers. You’ve automated data collection. So why are you still missing critical compliance data?

Welcome to the last-mile problem of compliance—the frustrating, final stretch where critical supplier information remains elusive. Whether it’s unresponsive suppliers, incomplete material declarations, or outdated certifications, closing these gaps is essential for achieving full compliance.

Let's explore why data gaps happen, how to close them, and what proactive steps you can take to prevent them in the future.

Why Do Compliance Data Gaps Happen?

Even the best compliance programs struggle with missing or incomplete data. Here’s why:

1. Unresponsive Suppliers

Some suppliers just don’t prioritize compliance data—until it affects their sales.

• They don’t fully understand the compliance requirements.
• They lack internal resources to gather the necessary documentation.
• They deprioritize compliance in favor of production and cost-cutting.

2. Incomplete Material Declarations

Even when suppliers respond, their data isn’t always useful:

• Missing CAS numbers for chemical compositions.
• Generic “compliant” statements without proper documentation.
• Exemptions that aren’t backed up with supporting evidence.

3. Legacy & Custom Parts

Older parts, custom-manufactured items, or proprietary formulations often lack full material disclosures because:

• No backup evidence or documentations available to certify compliance.
• The supplier no longer supports the part.
• Compliance regulations have changed since the part was first introduced.

4. Regulatory Changes

Newly restricted substances and updated reporting requirements can instantly create data gaps. What was compliant last year may now need additional validation.

How to Close Compliance Data Gaps

Filling in missing compliance data requires a mix of strategic outreach, internal collaboration, and risk-based prioritization. Here’s how:

1. Strengthen Supplier Communication

If suppliers aren’t responding, change your approach:

• Work through procurement teams—suppliers prioritize requests from buyers.
• Escalate through executive contacts if needed.
• Provide educational resources to help suppliers understand why compliance matters.

2. Prioritize High-Risk Components

Not all data gaps are equal. Focus on high-risk materials and components first:

• Parts containing metal alloys, coatings, and adhesives often have compliance risks.
• Electrical components may contain lead (Pb), cadmium (Cd), or brominated flame retardants.
• Chemicals and coatings can contain PFAS or other newly restricted substances.

Use risk assessment tools to prioritize which gaps to address first.

3. Utilize Third-Party Testing & Labs

For non-responsive suppliers or unverifiable data:

• Conduct XRF (X-ray fluorescence) testing for metal components.
• Use chemical analysis for plastics and coatings.
• Partner with accredited testing labs to generate missing compliance data.

4. Cross-Check Existing Data Sources

Sometimes the data already exists—you just need to find it:

• Design Drawings: Review custom part drawings to identify material standards such as ASTM, AISI, ASME, and others.
• Supplier Website: Check the supplier website for published compliance documents, as many provide these directly on their websites.
• Distributor Websites: – Explore distributor listings to verify compliance status for off-the-shelf (OTS) components.
• SDS/MSDS Documents – Analyze Safety Data Sheets (SDS/MSDS) to assess compliance risks associated with chemical substances.

5. Implement Supplier Compliance Incentives

Make compliance a win-win for suppliers:

• Prioritize compliant suppliers in sourcing decisions.
• Offer tiered recognition for suppliers who provide full material disclosures.
• Set clear response deadlines tied to procurement contracts.

Preventing Future Compliance Data Gaps

Closing today’s data gaps is important—but preventing them in the first place is even better. Here’s how:

1. Embed Compliance in Supplier Agreements

Make it contractually required for suppliers to:

• Provide compliance data before delivering materials.
• Respond to compliance inquiries within a set timeframe.
• Submit updated compliance documentation annually.

2. Leverage Full Material Disclosure (FMD)

Instead of chasing individual compliance certificates:

• Require Full Material Disclosure (FMD) for all components.
• Use compliance software to track and store supplier data centrally.
• Standardize data formats to avoid inconsistencies.

3. Automate Supplier Data Collection

Manual compliance tracking is outdated and inefficient. Instead:

• Use supplier portals for direct data submission.
• Automate compliance reminders and follow-ups.
• Integrate with ERP and PLM systems for real-time tracking.

4. Monitor Regulatory Updates Proactively

Stay ahead of regulatory changes before they create new data gaps:

• Subscribe to regulatory tracking services.
• Attend industry conferences on compliance updates.
• Set up internal alerts for substance list changes.

Final Thoughts: The Last Mile Matters

Your compliance program is only as strong as the weakest data point. By proactively closing gaps—and preventing new ones from forming—you create a resilient, future-proof compliance system.

So, take a moment to evaluate your data gaps. Where are the holes? What’s your strategy to fix them? If you don’t have one, now is the time to start by Leveraging Automation in Compliance Management, Work Smarter, Not Harder Ensuring Ongoing Compliance Throughout the Product Lifecycle—because compliance doesn’t end once the data is collected.