What are the phases of CBAM implementation?

The Carbon Border Adjustment Mechanism (CBAM) is being implemented in two phases: a transitional phase and a permanent phase.The CBAM transitional phase runs from October 1, 2023 to December 31, 2025 and requires EU importers to report the embedded greenhouse gas emissions of in-scope goods on a quarterly basis, without purchasing CBAM certificates.The CBAM permanent phase begins on January 1, 2026. From this point forward, importers must submit annual emissions declarations and purchase CBAM certificates to cover a growing share of embedded emissions, with full financial coverage required by 2034.

What is the Carbon Border Adjustment Mechanism (CBAM)?

The Carbon Border Adjustment Mechanism (CBAM) is an EU regulation that places a carbon price on certain imported goods based on their embedded emissions.CBAM is designed to prevent carbon leakage by ensuring imported products face a comparable carbon cost to goods produced within the EU under the EU Emissions Trading System (EU ETS). The regulation currently applies to carbon-intensive goods such as iron and steel, aluminum, cement, fertilizers, electricity, and hydrogen, and requires importers to calculate and report emissions using defined EU methodologies.

What is a CBAM certificate?

A CBAM certificate is a tradable unit that represents one tonne of CO₂-equivalent emissions embedded in imported goods subject to the Carbon Border Adjustment Mechanism.During the CBAM permanent phase, EU importers must purchase and surrender CBAM certificates annually to account for the emissions associated with their imports. Certificate prices are linked to the average EU ETS carbon price, and the number of certificates required may be reduced if a carbon price was already paid in the country of origin. Accurate supplier emissions data helps minimize certificate costs.

Why are suppliers receiving more data requests from customers?

Due to increasing geopolitical uncertainty, shifting buyer expectations, and rapidly evolving regulations, suppliers are facing significantly more inquiries about their product and supply chain data. Some suppliers have seen up to a 500% year-over-year increase in requests. Managing this increase with manual processes or spreadsheets is no longer sustainable. AI-native technology and expert support are now essential for keeping up.

How does Assent support suppliers in managing complex data requirements?

Assent combines AI-native automation with real human guidance. The platform simplifies data submission, allows you to upload data once and share it with multiple customers, and provides clear workflows. Meanwhile, supplier success specialists offer hands-on support, clarify requirements, provide training, and deliver supplier-focused education, turning overwhelming demands into manageable steps.

What benefits do suppliers gain from using the Assent Sustainability Platform?

The platform acts as a central hub for responding to customer requests quickly and accurately. Assent specialists help suppliers get set up, navigate the system, configure catalogs and parts, and remove roadblocks. This leads to higher submission rates, fewer errors, and reduced workload, especially with tools like Request Manager, which allows suppliers to manage all data requests in one place, even from companies not using Assent.

How does Assent ensure ongoing success for suppliers?

Assent’s approach includes proactive issue resolution and continuous product improvement. Supplier success specialists help identify problems early, prevent repeated issues, and streamline workflows. They also gather real supplier feedback that guides updates to the platform, campaign strategy, and overall customer success approach, ensuring the system continually aligns with supplier needs.

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FMD Management Solution

AI-Powered Full Material Disclosure (FMD) Software

Q: How often should FMD data be updated?

Because product materials change over time, it’s best practice to review and refresh FMD data annually. Assent’s automated update process validates supplier information, flags discrepancies, and keeps your compliance data aligned with the latest regulations, so you always have a current, audit-ready record.

Regularly collecting full material disclosures from your supply chain gives you critical insights into your compliance risks. Assent’s AI-powered FMD software automates data collection and analysis, helping you stay ahead of compliance risk.

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The Power of AI, the Confidence of Full Material Disclosures

Rapid Access to Supplier FMD Data

The Assent Sustainability Platform gives you and your suppliers a centralized hub to proactively share and request FMDs and other compliance declarations.

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Automate Supplier Material Disclosures With Assent

AI-Powered FMD Collection

Automate supplier outreach to prevent supplier fatigue and reduce the time and cost of FMD data collection.

Intelligent Full Material Disclosure Management

Efficiently collect, store, and analyze full material disclosures using standardized formats like IPC-1752A and IEC 62474. Reuse data across multiple programs to meet requirements for REACH, RoHS, TSCA, and more.

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FAQ: FMD Management

Get quick answers about full material disclosures (FMDs) and how Assent’s AI-powered software simplifies compliance and supply chain transparency.

What is a full material disclosure (FMD) or full material declaration?

A full material disclosure (FMD), also called a full material declaration, is a complete record of every material and substance in a product. Unlike partial declarations, an FMD provides full transparency down to the homogeneous level, enabling faster responses to REACH, RoHS, and other global regulations. By maintaining this data, manufacturers can improve risk visibility, reduce data requests, and design safer, more sustainable products.

How does Assent’s AI-powered FMD software simplify compliance management?

Assent’s platform automates supplier engagement, data collection, and validation using AI-driven workflows. It standardizes supplier inputs, identifies missing or invalid data, and continuously monitors regulated substances. With everything in one system, compliance teams can spend less time on manual tracking and more time on strategic sustainability initiatives.

What regulations and standards can a full material disclosure support?

A single FDM can help you meet multiple global regulations and reporting requirements. With complete substance-level data, you can efficiently demonstrate compliance with REACH, RoHS, Proposition 65, TSCA, MDR, POPs, and more. Because FMDs are built to recognized XML standards like IPC-1752A or IEC 62474, the data can be reused across programs, ensuring consistency, accuracy, and readiness for future regulatory changes.

What standards define an FMD, like IPC-1752A or IEC 62474?

FMDs follow recognized international data exchange standards to ensure interoperability and accuracy. The IPC-1752A standard supports RoHS and REACH reporting, while IEC 62474 is widely used in the electrotechnical industry to structure materials data. These formats allow manufacturers to share consistent, machine-readable data across suppliers, customers, and compliance systems.

How often should FMD data be updated?

Because product materials change over time, it’s best practice to review and refresh FMD data annually. Assent’s automated update process validates supplier information, flags discrepancies, and keeps your compliance data aligned with the latest regulations, so you always have a current, audit-ready record.

Case Studies

Better RoHS Data, Fewer Resources

eESCATEC, an electronic and mechatronic design and contract manufacturing company, needed a consolidated REACH and RoHS compliance program. They needed better data and faster reporting, without adding to their compliance workload. By implementing Assent’s RoHS compliance software, ESCATEC achieved a 50% improvement in program efficiency.

Benjamin Khor

Manager, Corporate Regulatory Compliance, ESCATEC

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Ryerson joined forces with Assent in 2020 to overhaul their compliance processes. Using Assent for product compliance, including TSCA PFAS, streamlined their operations and drove cost savings equivalent to 20 full-time salaries. The company has seen a 50% improvement in supplier outreach campaign completion time and accuracy, as well as a reduction in resources needed to achieve compliance.

Andrea Okun

Deputy General Counsel & Chief Compliance Officer, Ryerson

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