If your inbox looks like this…

“Hi, just following up on that Full Material Disclosure request…”
“Any update from your supplier?”
“Can you confirm CAS numbers for this part?”

You're not managing compliance — you’re firefighting.

Most companies spend more time chasing suppliers than managing risk. And the reason is simple: FMD expectations are vague, inconsistent, and buried in post-PO chaos.

It doesn’t have to be this way.

Here’s how the best teams streamline FMD collection — without the email chains, Excel mess, and endless follow-ups.

Start Early: Set FMD Expectations Upfront

The biggest mistake? Treating FMD like an afterthought. By the time the part is sourced or the PO is cut, you’ve lost leverage.

Instead:

  • Add FMD requirements directly into RFQs and sourcing templates
  • Make IPC-1752A Class D or equivalent a contractual obligation
  • Include turnaround timelines and accepted formats
  • Require declaration against known lists: REACH SVHC, RoHS, Prop 65, TSCA

If you expect 90%+ FMD completeness, make it known — and make it part of the deal.

Give Suppliers the Tools to Succeed

“We don’t know how” is a common excuse. But often, it’s true.

Many suppliers have never submitted an FMD before, or rely on outdated PDFs and manual processes.

Here’s what you should offer:

  • Free FMD templates (Excel-to-XML converters, IPC generators)
  • A supplier portal or upload form with validation rules
  • Training videos or onboarding guides
  • Examples of accepted files vs. rejected ones

The easier you make it, the more likely you are to get complete, correct data — on time.

Segment Your Suppliers (And Triage Your Efforts)

Not every supplier gets the same playbook. Tier 1 strategic suppliers may need direct engagement. Others may require a lighter touch or interim solutions.

Here’s how to think about it:

| Supplier Type | Strategy | |--------------------|-------------------------------------------| | Tier 1, high volume | Direct outreach, structured templates | | Tier 2, recurring | Pre-approved declaration formats + check-ins | | One-time/low-risk | Accept partial FMD + written confirmation |

Start with the suppliers that control the majority of your parts or risk exposure. Get them compliant. Expand from there.

Accept Partial FMDs — But Validate the Gaps

Suppliers may push back on “full” disclosure. That’s fine — to a point.

Industry best practice: allow up to 10% of materials to be marked as proprietary. But require a written statement confirming that no restricted substances are present in the confidential portion.

If there’s a 10% gap, you need 100% assurance it won’t trigger non-compliance.

Bonus: request supporting SDS or test reports for any flagged parts or exemptions.

Don’t Wait for Regulators to Set the Deadline

REACH updates twice a year. New SVHCs are added. RoHS thresholds evolve. Prop 65 changes.

If you only request FMDs when the regulation hits — you’re already behind.

Instead:

  • Build a schedule to refresh FMDs annually or bi-annually
  • Use automation to monitor substance list updates
  • Re-validate flagged parts proactively

This isn’t about one-time compliance — it’s about supply chain visibility.

Final Word: Chasing Is Not a Strategy

You can’t scale FMD with reminders, spreadsheets, and supplier “maybes.”
You need a system. One that supports onboarding, validation, follow-up, and traceability — at speed.

That’s what we built at Acquis.

  • Supplier onboarding workflows
  • CAS validation
  • Exemption tracking
  • Structured XML generation
  • Document capture
  • Analytics

And most importantly:
No more chasing. Just clean, audit-ready data — on demand.

Want to see how it works?

Let’s connect — We’ll show you how to go from 30% FMD coverage to 90%+ in weeks.

Speak to Our Compliance Experts

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