Frequently Asked Questions 


CDX (Compliance Data Exchange) is:
Compliance: CDX enables participating companies to comply with the most well-known global legal requirements and definitions such as REACH (incl. Annex XIV and XVII, REACH SVHC, REACH O5A), China RoHS, RoHS (with full support of exceptions), California Proposition 65, IPC1752A Class C and D, IEC62474, Batteries, Packaging, ELV / GADSL, HKC, and Conflict Minerals.
Data: CDX can help you efficiently gather, store, and report detailed product content information for use in compliance and material reporting to various government agencies worldwide.
Exchange: CDX addresses the data throughout the entire supply chain, not just immediate suppliers and customers. With CDX, information is aggregated through all levels of the supply chain in a comprehensive manner while protecting intellectual property.
CDX is a centrally operated and supported service by DXC Technology (DXC) that allows for standardized creation and exchange of Material Data Sheets (product structures, MDSs), as well as Conflict Minerals Declarations (CMDs) throughout the supply chain. CDX provides a robust repository employing respected chemical, material, and legislative support agencies to ensure CDX companies have the resources for accurate reporting.
CDX features a centralized and secure cloud-based application optimized for manufacturers in virtually any industry, and requires little or no IT infrastructure to implement as it is accessible by anyone with a link to the public internet.
A user can register for CDX (using a self-service process) and begin reviewing and using some basic features without signing a license contract.
The CDX platform allows companies to promote material compliance and environmental sustainability via the creation, exchange and maintenance of Full Material Declaration (FMD) Material Data Sheets (MDSs) throughout the entire supply chain.

CDX helps identify what is in your products, how supplied ingredients were produced, and what impact these have upon your business operations.
Toxic heavy metals and other hazardous substances in products come into contact with people during product use, and enter the environment via improperly disposed products, contaminated water, incineration processes, and garbage. These harmful substances are then ingested by humans directly or enter the food chain via absorption in the air, water, minerals, plants and animals. To protect the health of people, the use and disposal of products containing these substances is regulated. In some cases use of these substances is restricted, while in other cases there is a complete ban on the use or uncontrolled disposal.
Implementing strategies to reduce, reuse and recycle (RRR) these substances has produced broader visibility into social responsibility concerns pertaining to product manufacture, such as fair labor and responsible material sourcing practices. These social responsibility concerns have spurred additional legislation and new customer reporting obligations.
The best known environmental and social regulations are listed here. A large and growing quantity of national and international legislation exists, with significant new and revised legislations appearing in many nations several times per year.
ELV - The European Union End of Life Vehicle (ELV) directive was the first modern environmental legislation of its kind, and was originally aimed at the reduction of heavy metal contamination in waste arising from the repair and disposal of automotive vehicles. The scope has since expanded. ELV is primarily addressed in the International Material Data System (IMDS), which we developed specifically for the Automotive industry. IMDS use is prohibited for most non-Automotive usage and supports only Automotive-relevant legislations, giving rise to the need for CDX.
REACH - The European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) is one of the broadest and most complex of the environmental regulations. The scope includes investigation of all chemicals and impacts virtually every industry. The aim is to identify all chemicals in use, ban the use of substances of very high concern (SVHC), and replace SVHCs with technically and economically feasible alternatives.
RoHS - The European Union Restriction of Hazardous Substances (RoHS) directive was modelled after ELV, and restricts the use of specific hazardous substances in most products containing electrical and electronic components.
China RoHS - Modelled upon yet noticeably different than the European version, the Chinese government's Restriction of Hazardous Substances (RoHS) applies to all items shipped into China and controls certain metals and polymer additives.Back to Top
California Proposition 65 (The Safe Drinking Water and Toxic Enforcement Act of 1986) - Leveraging substance lists developed for REACH, this California law prohibits businesses from knowingly discharging listed substances into drinking water sources, or onto land where the substances can pass into drinking water sources. It also prohibits businesses from knowingly exposing individuals to listed substances without providing a clear and reasonable warning.
Conflict Minerals - Section 1502 of the Dodd-Frank Act requires companies that use tin, tungsten, tantalum and gold (3TG) in their products or in the production of their products to disclose that information annually with the Securities and Exchange Commission (SEC). Non-SEC filers in all regions of the world who are part of the supply chain for these filers are typically required contractually to support their customers. New Conflict Mineral legislations are currently being defined in the EU and in Asia.
U.K. Modern Anti-Slavery - Enacted by the U.K. Parliament in 2015, this legislations provides for the seizure of assets of any entity engaged or employing within their supply chain (even at several steps removed) those engaged in slavery or human trafficking and conducting commerce within the U.K.
Clear identification and reporting of materials used in the supply chain is needed to comply with these legislations. Identification of all substances, and not just those currently legislated, provides a measure of efficiency and protection against future legislation changes and additions. Without standardized, secure processes and independently hosted cloud-based tools it is extremely difficult, if not impossible, to exchange defined data throughout a global supply chain. With CDX, you can collect and provide information about the materials contained in your products or used during your production process through the entire supply chain. You can analyze the data in terms of environmental compliance and have complete trust that this data is handled safely and confidentially.
Knowledge of product content and supply chain procurement practices offer business opportunities to develop strategies designed to provide more efficient ways to obtain, manufacture and employ their products and supply chain, thus reducing costs, waste, and risk. A growing number businesses and consumers prefer or choose exclusively to purchase from environmentally friendly and socially responsible product providers.
While the compliance legislations often provide the initial impetus to investigate product and supply chain topics, the collateral benefits often drive investigation into advantages far beyond regulatory compliance.

DXC's Compliance Data Exchange (CDX) can help you efficiently gather, store, and report product content for use in compliance and material reporting to various government agencies worldwide.
By using CDX, you can:

- Capitalize on your supply chain's knowledge by using established standards, procedures, and services.
- Become a green corporate citizen while minimizing your reporting costs.
- Communicate product content with your suppliers and customers in real time.
- Stay ahead of new requirements by analyzing existing product content and planning where changes are needed.
- CDX addresses the entire supply chain, not just immediate suppliers and customers. With CDX, information is aggregated through all levels of the supply chain in a comprehensive manner while protecting intellectual property.
- CDX uses a product-centric model, which helps companies retain focus upon their product and provide information once for all supported regulations, instead of a regulation-centric model, which requires the same information be provided again for each regulation.

The robust CDX Conflict Minerals Declaration (CMD) Manager aggregates internal and multi-tier supplier CMDs for faster, easier and less complex customer and SEC reporting. It supports and leverages all released versions of the Responsible Minerals Initiative (RMI, formerly CFSI) Conflict Minerals Reporting Template (CMRT), yet provides options for more complete and flexible information gathering.
The CDX CMD Manager also leads the industry in providing the most complete smelter information available. This includes standard smelters, RMI Conflict-Free smelters, those registered in CDX, alleged smelters, and distributors and other facilities.
CDX CMD Manager helps you manage your CMDs in a variety of ways depending upon your situation, including importing and exporting the RMI Excel CMRT, the IPC1755 data exchange standard, and sending and receiving CMDs to and from other companies registered in CDX.

With CDX you can send a request for a Material Data Sheet (MDS) or a Conflict Minerals Declaration (CMD) to your suppliers. These companies can be registered in CDX or they can be companies that have not registered in CDX.
Your supplier can respond to the request by registering in CDX, entering the MDS or CMD information and sending the MDS or CMD back to the requesting company. Please note that there is no cost for your supplier to use CDX to create and send an MDS or CMD to their customers. A CDX license is needed to request and receive MDSs or CMDs from suppliers and integrate them into your own MDS or CMD.
Having suppliers submit directly into CDX eliminates the risks associated with e-mail, better secures and protects their information, and ensures their information does not get lost.
For material data reporting, importing and exporting based on the IPC1752A standard is also available.
For Conflict Minerals Declarations (CMDs), if your supplier does not register in CDX, but chooses to send you a RMI Excel CMRT, you can easily import the CMRT into CDX.
Whether you receive supplier CMD information through the CDX system or you have imported your supplier's CMRT, you can then use that supplier information and aggregate it into your own CMD. This saves manual effort, time and money while providing a better overview, higher quality data and faster access to information for compliance reporting. CDX places the responsibility of providing accurate, meaningful material and source information upon the supplier, instead of the customer.

There are many benefits for your suppliers when they use CDX. If creating Material Data Sheets (MDSs) for a product or material, they can create one MDS and use it to respond to requests from multiple customers. In the same way, one Conflict Minerals Declaration (CMD) can be sent to multiple customers (if customer in CDX). A supplier code can be added for each customer's response without creating a new MDS or CMD. CDX also provides active warnings and checking, permitting the supplier to fix issues once rather than addressing them repeatedly for each customer.
If your supplier has customers that are not in CDX, they can export the RMI Excel CMRT for sending to their non-CDX customers. If importing their existing CMRT into CDX, they only need to import one time and then use that imported CMRT to respond to multiple customer requests. Quality data is provided by suppliers to their customers by performing CDX system checks and validation before the MDS or CMD is sent to the customer.
CDX can also be used by your suppliers to send MDS or CMD requests to their own suppliers to gather the information they need for their own declarations.

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