Material Compliance in the U.S. Market
Material compliance is a global imperative — essential for manufacturers, importers, and suppliers striving to build safe, sustainable, and legally compliant products. In the United States, compliance takes on added complexity due to a patchwork of federal and state-level regulations, such as the Toxic Substances Control Act (TSCA), California Proposition 65, and the Dodd-Frank Act’s Conflict Minerals Rule. These laws require full transparency across the supply chain and strict documentation of chemical and material data.
For companies operating in highly regulated industries — particularly automotive, electronics, and mobility — failure to manage material compliance effectively can result in regulatory penalties, blocked imports, delayed product launches, or reputational damage.
TSCA, Prop 65 & Supply Chain Pressure
In the United States, TSCA risk evaluations and reporting obligations are becoming increasingly stringent under the EPA’s expanded authority. Companies must now account for how substances are used, exposed, and disposed of — not just in their own operations, but throughout their supply chains. This includes evaluating the presence of high-priority chemicals and submitting comprehensive chemical data reporting (CDR) when required.
At the state level, California Proposition 65 continues to drive material compliance action across industries. With its constantly evolving list of over 900 substances, Prop 65 has a significant impact on labeling, packaging, and retailer obligations — even for companies that don’t operate directly in California. Recent waves of enforcement by private plaintiffs have pushed manufacturers and importers to re-examine product formulations and supplier declarations at every level.
As OEMs and Tier 1s increasingly pass compliance responsibilities downstream, suppliers must be ready to prove substance-level transparency, validate documentation, and manage cross-border compliance simultaneously.
EFS Consulting Americas: Material Compliance Services for the U.S. Market
EFS Consulting Americas supports companies in meeting U.S. material compliance standards with structured systems, proactive monitoring, and supplier engagement strategies. Our team helps you build resilience by navigating the complexities of chemical data management, substance tracking, labeling, and documentation — ensuring your materials meet current U.S. regulatory requirements and prepare you for future legislative shifts.
Our tailored approach addresses the full lifecycle of material compliance — from initial awareness and supply chain data gathering to regulatory monitoring and certificate management. We work hand-in-hand with your compliance, procurement, and engineering teams to ensure operational readiness and market access.
- Material Compliance Awareness Check
- Material Compliance Management System
- Supply Chain Task Force
- Product Composition Review
- Early Warning System
- Regulatory Analyses
- Safety Data Sheets
- Conflict Minerals and Global Reporting
1. Material Compliance Awareness Check
Many companies underestimate their exposure to U.S. material regulations until it’s too late. We assess your organization’s awareness, maturity, and risk posture regarding TSCA, Prop 65, and conflict minerals through targeted evaluations and readiness assessments.
EFS Consulting Americas Services:
- Risk assessment and process audits
- Review of compliance roles and responsibilities
- Regulatory exposure mapping
- Remediation planning
2. Material Compliance Management System
A centralized, structured compliance management system is critical to ensure product and supplier data are accurate, traceable, and audit-ready — especially when facing EPA inspections or OEM audits.
EFS Consulting Americas Services:
- Definition of internal workflows and ownership
- Digital tool selection and integration (e.g., IMDS, BOMcheck)
- Supply chain data validation processes
- Compliance documentation and retention strategy
3. Supply Chain Task Force
Supplier engagement is key to U.S. compliance — especially with global suppliers unaware of U.S. Prop 65 or TSCA reporting obligations. EFS Consulting Americas facilitates targeted campaigns to collect, verify, and manage chemical composition data.
EFS Consulting Americas Services:
- Supplier onboarding and training
- Conflict minerals documentation support (CMRT)
- SDS collection and validation
- Stakeholder communication and escalation
4. Product Composition Review
We screen your components and materials against regulated substance lists, ensuring your products comply with U.S. and global regulations.
EFS Consulting Americas Services:
- TSCA/Prop 65 substance screening
- Conflict minerals review
- SVHCs (e.g., per EU REACH for export markets)
- Labeling requirements and exemptions
5. Early Warning System
EFS Consulting Americas maintains an early warning system tailored to U.S. federal and state regulations, monitoring legislative developments across the country.
EFS Consulting Americas Services:
- Regulatory trend reports (EPA, California OEHHA, state-level bans)
- Impact analysis and internal dissemination
- Custom dashboards and alerts
6. Regulatory Analyses
Our compliance experts provide legal-technical insights into complex substance regulations, tailored to your industry and materials.
EFS Consulting Americas Services:
- Applicability assessment (e.g., TSCA vs. REACH for exports)
- Interpretation of EPA rules and Prop 65 listings
- Compliance strategy development
- U.S.-specific product labeling analysis
7. Safety Data Sheets (SDS)
Ensure your SDS documentation meets both GHS and OSHA HazCom 2012 standards, while accommodating U.S.-specific nuances such as California ingredient disclosures.
EFS Consulting Americas Services:
- SDS creation and gap analysis
- Classification under U.S. GHS
- Multilingual adaptations
- Periodic review and version control
8. Conflict Minerals and Global Reporting
Compliance with Section 1502 of the Dodd-Frank Act requires disclosure of the origin and due diligence processes for tin, tungsten, tantalum, and gold. EFS Consulting Americas supports both downstream and upstream companies in maintaining compliant reporting.
EFS Consulting Americas Services:
- CMRT collection, validation, and consolidation
- Smelter due diligence and outreach
- SEC compliance support
- Internal documentation and audits
Ready to Ensure Full Material Compliance in the U.S.?
EFS Consulting Americas is your trusted partner for scalable, audit-ready compliance solutions — built on industry expertise and regulatory insight. Whether you’re supplying to U.S. OEMs or entering the North American market, we’ll help you ensure your materials, supply chain, and data stay compliant.
