Declare RL-002b Small Electrical Components Supplier Advocacy Letter

Why use the advocacy letter?

Small electrical components are found in many building products, including lighting, controls, equipment, and other electrical assemblies. However, full ingredient disclosure to the CASRN level remains uncommon across the electrical components supply chain. 

The Declare and LBC Small Electrical Components exception (RL-002a and RL-002b) recognizes this challenge. The exception allows certain small electrical components to be used when they comply with the EU RoHS (Directive 2015/863), even when full ingredient disclosure is not available. RoHS 3 establishes restrictions on selected substances, including certain heavy metals, phthalates, and brominated flame retardants. 

RoHS is an important step, but it does not address every chemical of concern on the Living Future Red List. Printed circuit boards and other electrical components, for example, may contain Red List substances that are not restricted under RoHS. 

The Small Electrical Components Supplier Advocacy Letter gives manufacturers a simple way to engage their suppliers on these remaining gaps. By asking suppliers about material transparency, safer alternatives, and ongoing improvements, manufacturers can help create demand for more transparent and healthier electrical components—and reduce reliance on the exception over time.

When should I use the letter?

The advocacy letter is optional. You do not need to send it to suppliers in order to use the RL-002b exception or to submit a Declare label.

Consider using the letter when you want to:

• Encourage suppliers to provide more information about the materials in their electrical components.
• Understand what safer material options may already be available.
• Learn about supplier efforts to reduce chemicals of concern.
• Identify barriers to greater ingredient transparency.
• Build a record of ongoing supply-chain engagement that can inform future product improvements and disclosures.

You may send the letter to all relevant electrical component suppliers or select suppliers where additional information would be particularly useful.

How to use the letter:

1. Download the template letter.
2. Customize the letter:  Transfer the template to your company letterhead and complete the applicable fields, including the supplier name, your name and title, and your company name. You may also adapt the introduction or questions to reflect your products and your relationship with the supplier. The template is intended as a starting point rather than a required form.
3. Send the letter to your SEC suppliers:  Send the completed letter to selected suppliers of small electrical components covered by your Declare submission. You may wish to send the letter as part of your normal supplier communication or procurement process. Consider giving suppliers an opportunity to provide existing documentation or other information they already have rather than asking them to create new documentation specifically for this request.
4. Share what you learn: If suppliers respond, you may upload their responses or supporting documentation to the Geofund platform with your Declare submission. You may upload supplier responses directly, or provide a summary of the key information received. There is no required format for supplier responses.

Information that may be useful includes:

• RoHS 3 compliance information
• Availability of halogen-free PCB laminates
• PVC-free or LSZH cable options
• Information about intentionally added brominated flame retardants
• Information about intentionally added PFAS
• Ingredient disclosure at the homogeneous material level
• Supplier initiatives related to safer chemistry or material transparency
• Barriers preventing greater ingredient disclosure

What if my supplier cannot provide the information?

That’s okay! The advocacy letter is intended to open a conversation, not create an additional documentation requirement.

Electrical component supply chains can be complex, and suppliers may not have access to all of the requested information. They may also need to protect proprietary information.

If a supplier cannot provide complete information, consider sharing whatever response or explanation they are able to provide. Information about the barriers suppliers encounter can be just as useful as a complete disclosure, because it helps identify where greater transparency and safer alternatives are still needed.

How Living Future uses this information

Supplier advocacy helps Living Future better understand the current state of material transparency and safer chemistry in the electrical components supply chain.

Over time, information gathered through manufacturer and supplier engagement can help identify:

• Where greater ingredient transparency is becoming available.
• Which safer materials and alternatives are entering the market.
• Where significant supply-chain barriers remain.
• How the electrical components industry is progressing beyond current regulatory requirements.

This information can help inform future program development and continued efforts to improve material health in building products.

Template Letter

Download the RL-002b Small Electronic Components Supplier Advocacy Letter

The completed letter should be submitted through the Geofund platform with the associated Declare submission.

Thank you for engaging your suppliers and helping move the electrical components market toward greater transparency and healthier materials.

Getting Help

If you have questions about the Declare label process and information, contact declare.support@living-future.org. Declare also hosts regular office hours; sign up here.