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When requesting RoHS REACH component documentation from electronic component suppliers, procurement and compliance teams must collect four distinct file categories: (1) Substance Compliance Declarations (RoHS Certificate of Compliance/Conformity and REACH Article 33 SVHC statements), (2) Material Composition Disclosures (Full Material Disclosures or FMDs), (3) Analytical Laboratory Test Reports (empirical chemical testing per IEC 62321 methods), and (4) Batch and Lot Traceability Documents (linking physical reel labels to compliance paperwork at incoming inspection). Crucially, a supplier's compliance declaration is a legally binding attestation—never an empirical laboratory test conclusion.
Before requesting every possible report for every line item on a Bill of Materials (BOM), use this risk-based triage framework to match documentation rigor to component risk:
0.1% weight by weight (w/w).| Document Category | Specific Files to Request | What It Proves (Legal vs. Empirical) | When to Request (RFQ vs. Receiving) |
|---|---|---|---|
| 1. Substance Compliance Declarations | RoHS CoC/DoC, Annex III/IV Exemption Statement, REACH Article 33 SVHC Declaration, Article Safe Use Statement | Legal attestation: Binds the manufacturer or supplier to conformity claims and discloses SVHCs above 0.1% w/w. Does not provide raw chemical measurements. |
RFQ / Onboarding (refresh when ECHA updates the SVHC list or upon PCN). |
| 2. Material Composition Disclosures | Full Material Disclosure (FMD), typically exchanged in IPC-1752A or IEC 62474 schema | Declared mass balance: Breaks down homogeneous materials and chemical substances by CAS number and weight percentage. | RFQ / Engineering Qualification (used to screen against future SVHC additions). |
| 3. Analytical Laboratory Test Reports | Accredited lab test report referencing IEC 62321 methods (e.g., XRF screening + wet chemistry / GC-MS) | Empirical measurement: Proves the chemical concentrations of a specific tested physical sample or production batch. | RFQ / Part Qualification (or per-batch for custom/high-risk materials). |
| 4. Batch & Lot Traceability Documents | Shipment Lot CoC, Packing List, OCM Reel/MBB Bar-Code Labels (MPN, Pb-Free Suffix, Lot/Date Code) | Physical custody link: Connects the physical components on the receiving dock to the approved compliance certificates. | Every Shipment at Incoming Inspection (IQC). |
Accepting incomplete or outdated compliance paperwork during part setup or warehouse receiving creates a direct legal vulnerability for original equipment manufacturers (OEMs) and contract electronics manufacturers (CEMs). While EU RoHS and EU REACH are almost always requested together during component onboarding, they operate under fundamentally different legal mechanisms, calculation denominators, and update cycles.
Under EU RoHS Directive 2011/65/EU[4] (as amended by Commission Delegated Directive (EU) 2015/863), electrical and electronic equipment (EEE) placed on the EU market must restrict 10 hazardous substances:
Four heavy metals: Lead (Pb), Mercury (Hg), Hexavalent Chromium (), and Cadmium (Cd).
RoHS concentration limits apply at the homogeneous material level—meaning any single material that cannot be mechanically disjointed into different materials (such as the thermoplastic housing of a connector, the epoxy molding compound of an IC, or the tin-silver-copper plating on a leadframe). As reflected in standard component declarations like TE Connectivity's EU RoHS compliance statements[8], nine of the restricted substances are capped at a maximum concentration of 0.1% by weight (1,000 ppm) in any homogeneous material, while Cadmium is strictly capped at 0.01% by weight (100 ppm).
Many procurement teams assume RoHS compliance is solely an environmental formality. In reality, RoHS is a CE-marking directive. According to the European Commission Staff Working Document on RoHS technical assessment[5], EN IEC 63000:2018 (Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances) is the official harmonised standard governing the technical documentation manufacturers must compile to demonstrate RoHS conformity (replacing the withdrawn EN 50581:2012 standard).
EN IEC 63000:2018 establishes a risk-based framework: rather than requiring OEMs to perform destructive chemical testing on every passive resistor and integrated circuit in a product, the standard allows manufacturers to assemble their technical file using verified supplier declarations, contractual agreements, material disclosures, and targeted analytical test reports. Consequently, if your procurement or IQC team accepts an expired, unsigned, or mismatched supplier declaration, your final product's EN IEC 63000:2018 technical file becomes defenseless during a national market surveillance audit.
Unlike RoHS, EU REACH (Regulation (EC) No 1907/2006) governs chemicals across all industries, affecting electronic components primarily through Article 33 (communication of Substances of Very High Concern in articles) and Annex XVII (substance restrictions).
When evaluating complex electronic assemblies, buyers must follow the European Court of Justice and ECHA "Once an Article, Always an Article" rule. According to ECHA's summary guidance on substances in articles[1] and the comprehensive ECHA guidance on requirements for substances in articles[2], the communication duties under REACH Article 33(1) apply to each individual constituent article within a complex object whenever a Candidate List SVHC is present above 0.1% weight by weight (w/w).
For an electronics manufacturer, this means you cannot dilute an SVHC's weight against the total weight of a finished printed circuit board assembly (PCBA). If an individual brass standoff, diode internal die-attach, or connector pin contains an SVHC above 0.1% w/w of that individual sub-article's weight, the supplier is legally obligated to declare the substance name and provide safe use information.
When a component crosses the 0.1% w/w REACH SVHC threshold, it also triggers waste-stage reporting obligations in the European Union. As detailed in ECHA's official SCIP database Q&A[3], under Article 9(1)(i) of the EU Waste Framework Directive (2008/98/EC), EU manufacturers, importers, and assemblers placing articles on the EU market that contain a Candidate List SVHC above 0.1% w/w must submit a dossier to the SCIP database (Substances of Concern In articles as such or in complex objects (Products)). Without accurate component-level SVHC data from upstream suppliers at the RFQ stage, EU importers and OEMs cannot generate valid SCIP notifications.
| Regulatory Framework | Legal / Standard Basis | Calculation Denominator | Substance Scope | Exemption Mechanism | Mandatory Supplier Output |
|---|---|---|---|---|---|
| EU RoHS | Directive 2011/65/EU + Delegated Directive (EU) 2015/863 + EN IEC 63000:2018 | Each homogeneous material within the component (≤0.1% w/w; Cadmium ≤0.01% w/w). |
10 restricted substances (4 heavy metals, 2 flame retardants, 4 phthalates). | Time-limited technical exemptions under Annex III and Annex IV (e.g., 6(c), 7(a), 7(c)-I). | RoHS CoC/DoC (citing explicit Annex III/IV exemptions if claimed) + FMD or IEC 62321 report per risk tier. |
| EU REACH (SVHC) | Regulation (EC) No 1907/2006 (Article 33 & Candidate List) | Each individual article / sub-component in a complex object (>0.1% w/w). |
Expanding ECHA Candidate List of SVHCs (typically updated twice a year by ECHA). | None for communication: Presence >0.1% w/w requires mandatory disclosure even if RoHS-exempt. |
REACH SVHC Declaration (citing active list date) + Substance Name/CAS + Article Safe Use Statement. |
| EU WFD SCIP | Waste Framework Directive 2008/98/EC Article 9(1)(i) | Each individual article containing a Candidate List SVHC (>0.1% w/w). |
Same as ECHA REACH SVHC Candidate List. | No exemption for articles placed on the EU market above threshold. | SCIP Notification Number or component material/TARIC data enabling downstream SCIP filing. |
Demanding third-party chemical lab reports for every standard surface-mount resistor will stall your procurement timeline, while accepting a generic one-page self-declaration for a custom plastic housing or broker-sourced IC exposes your line to recalls. Applying the risk-based methodology of EN IEC 63000:2018 alongside supply chain verification practices outlined by TTI MarketEye, DigiKey, Altium, and SiliconExpert, teams should scale their documentation requests across three operational axes.
Original Component Manufacturers (OCMs) issue compliance certificates in two distinct structural scopes. Looking at Panasonic Industry's RoHS/REACH Confirmation Report portal[6], buyers can download confirmation reports either by individual Part Number or by Product Series.
When a Part-Number-Specific Report is Mandatory: If a product family offers both legacy tin-lead () finishes for aerospace/defense and lead-free ( or matte tin) finishes for commercial electronics, a generic family letter is insufficient. You must request a part-number-specific confirmation covering the exact ordering suffix.
Not all electronic materials carry equal chemical risk:
4% lead (Exemption 6(c)).High-Risk Polymer & Plating Parts: Flexible PVC wire harnesses, heat-shrink tubing, rubber gaskets, O-rings, and adhesives carry high risk for restricted phthalates (DEHP, BBP, DBP, DIBP), while custom sheet-metal brackets and fasteners carry hexavalent chromium () passivation risks.
An OCM or authorized distributor (as detailed in DigiKey's guide to RoHS and REACH approved components) maintains direct digital links to factory material declarations and Product Change Notifications (PCNs). Conversely, custom build-to-print mechanical vendors or unvetted secondary suppliers require empirical verification. To prevent compliance files from sitting disconnected in email folders, engineering teams should integrate part-level exemption codes, FMD files, and SVHC status directly into their active component database using effective electronics BOM management practices.
| Component & Sourcing Scenario | Risk Level | Minimum Document Package to Request | Why Escalating (or De-escalating) Matters |
|---|---|---|---|
| Standard catalog passives/ICs (no exemptions) via OCM or franchised distributor | Low | Part-Number or verified Series-Level RoHS CoC/DoC + dated REACH SVHC Declaration + Shipment Lot CoC. | De-escalating from mandatory lab testing saves onboarding time while satisfying EN IEC 63000 low-risk assessment rules. |
| Components claiming RoHS Annex III/IV exemptions (e.g., 6(c), 7(a), 7(c)-I) | Medium-High | RoHS CoC explicitly citing the exemption code + Full Material Disclosure (FMD) + REACH Article 33 SVHC Declaration (>0.1% w/w Lead) & Safe Use / SCIP data. | Lead allowed by RoHS exemption usually exceeds 0.1% w/w of the sub-article, triggering mandatory REACH SVHC and SCIP reporting. |
| Multi-material assemblies, connectors, or parts on long-lifecycle industrial/medical BOMs | Medium-High | Full Material Disclosure (FMD in IPC-1752A / IEC 62474 format) + RoHS/REACH CoC + Lot CoC. | FMDs list CAS numbers by weight, allowing instant internal BOM re-screening whenever ECHA adds new SVHCs every six months. |
| Custom cables, PVC/elastomers, custom platings, or newly onboarded contract manufacturers | High | Signed Supplier RoHS/REACH Declaration on your official template + Analytical Lab Test Report (IEC 62321 for all 10 substances) + Batch Traceability. | Flexible polymers and custom plating baths carry high risk of phthalate plasticizer or cross-contamination. |
| Spot-buy or independent channel sourcing for shortage/obsolete ICs | Critical | OCM original RoHS/REACH status + Lot/Batch Traceability + XRF/Analytical Verification + Decapsulation/Solderability inspection. | Prevents remarked leaded () legacy parts or counterfeit lots with fabricated PDF certificates from entering SMT lines. |
To build an audit-ready technical file—as outlined in industry frameworks such as Enviropass's RoHS and REACH compliance assessment guide and Altium's supply chain compliance documentation guide—procurement and quality engineers must understand what each of the four document types can and cannot prove.
A Certificate of Compliance (CoC) or Declaration of Conformity (DoC) is a formal legal statement signed by an authorized representative of the manufacturer or supplier affirming that specified parts comply with EU RoHS and/or REACH regulations. In B2B manufacturing, submitting this declaration is a standard contractual obligation, as illustrated in the Piher Sensors & Controls Supplier Manual[7], which requires suppliers to provide formal Certificate of Compliance letters for both RoHS and REACH/SVHC during qualification.
When a component contains a REACH Candidate List SVHC above 0.1% w/w, the declaration cannot simply state "Compliant" or "Non-Compliant." Under REACH Article 33, the supplier must identify the SVHC and provide Article Safe Usage Statements. For example, real-world component documentation such as Distrelec's component technical datasheet and safe use documentation includes explicit safe handling, industrial hygiene (e.g., "Do not eat, drink or smoke when using this product"), and end-of-life recycling instructions when restricted or declarable substances are present.
0.1% w/w.A Full Material Disclosure (FMD) is an engineering bill of materials for the chemical makeup of the component itself. It breaks the component down into each constituent homogeneous material (silicon die, die-attach adhesive, gold bond wire, copper leadframe, epoxy molding compound, matte tin termination plating) and lists the exact chemical substances by CAS (Chemical Abstracts Service) number and weight/mass percentage.
As noted in JAK Electronics' procurement and engineering compliance guide, electronics supply chains commonly exchange FMD files using standardized machine-readable schemas such as IPC-1752A (Classes C and D XML/PDF formats) or IEC 62474 (the electrotechnical industry material declaration standard; automotive electronics teams similarly rely on the International Material Data System, or IMDS, to submit material composition proof).
An Analytical Laboratory Test Report documents empirical physical and chemical testing performed on a specific component sample by an accredited testing laboratory (typically ISO/IEC 17025 accredited) following IEC 62321 test methods (Determination of certain substances in electrotechnical products). Standard IEC 62321 testing involves non-destructive X-Ray Fluorescence (XRF) screening for heavy metals (Pb, Hg, Cd, total Cr, total Br), followed by wet-chemical confirmation (such as UV-Vis for ) and Gas Chromatography–Mass Spectrometry (GC-MS) to measure the four restricted phthalates (DEHP, BBP, DBP, DIBP).
One of the most frequent compliance failures in electronics procurement is confusing a Supplier Declaration with a Laboratory Test Report. As highlighted in TTI MarketEye's analysis of RoHS test requirements vs. certificates of compliance, these two documents serve completely different functions—and substituting one for the other triggers immediate quality rejections:
RoHS_Test_Result.pdf) by itself. Customer quality auditors reject this immediately because a lab report only certifies the chemistry of the individual sample sent to the lab—it is not a legally binding declaration signed by the supplier warranting the ongoing production parts shipped under your purchase order. For high-risk or automotive/industrial parts, you need both: the underlying IEC 62321 test report as empirical proof ("no report, no declaration"), and the signed Supplier Declaration executed on the required compliance template.RoHS Made Simple: Everything You Need to Know
0.1% (or 0.01% for Cd) of all 10 RoHS substances.
Even the most thorough RoHS CoC, IPC-1752A FMD, and IEC 62321 lab report are worthless during an inspection if your warehouse receiving team cannot prove that those PDF files apply to the physical reels sitting on the loading dock. Batch and Lot Traceability Documents include the Shipment Certificate of Conformance (Lot CoC), Packing List, and the original component manufacturer's bar-code labels on the moisture barrier bag (MBB) and inner reel.
These documents bind the physical Manufacturer Part Number (MPN), lead-free ordering suffix, Date Code, and Lot/Batch Number to your compliance file. Traceability breakdowns are especially dangerous when buyers turn to unvetted secondary markets during shortages. Reviewing the common mistakes to avoid when sourcing ICs online reveals how non-authorized brokers frequently attach generic, outdated, or scraped OCM RoHS PDFs to shipments of legacy tin-lead () or remarked components whose lot codes have zero connection to the attached paperwork.
| Attribute | 1. Substance Compliance Declaration (CoC / DoC) | 2. Material Composition Disclosure (FMD) | 3. Analytical Lab Test Report | 4. Batch / Lot Traceability File |
|---|---|---|---|---|
| Primary Purpose | Legally binds supplier to RoHS/REACH conformity & discloses SVHCs >0.1% w/w. |
Discloses 100% homogeneous material & chemical CAS breakdown by weight. | Empirically measures chemical concentration in a physical sample. | Links physical shipped reels/trays to the approved MPN and compliance file. |
| Standard / Legal Basis | EU 2011/65/EU, (EU) 2015/863, REACH Art. 33, EN IEC 63000:2018. | Commonly formatted to IPC-1752A or IEC 62474 (or IMDS in auto). | Tested per IEC 62321 methods by an ISO/IEC 17025 lab. | ISO 9001 / AS9100 / IATF 16949 lot control & OCM label standards. |
| Contains Empirical Lab Data? | No (Legal attestation only). | No (Calculated mass balance from material specs). | Yes (XRF, wet chemistry, GC-MS results in ppm / % w/w). |
No (Manufacturing lot, date code, and suffix confirmation). |
| Survives Future ECHA SVHC Updates? | No (Must request a new letter whenever ECHA updates the list). | Yes (CAS numbers on file can be re-screened internally against new SVHCs). | No (Only tests for specific substances targeted during the lab run). | N/A (Applies strictly to the physical shipment batch). |
| When It Fails an Audit | Missing 2015/863 reference, undated REACH list, or unrecorded RoHS exemption. | Exceeds allowable trade-secret threshold or omits homogeneous layer weights. | Only covers 6 legacy RoHS substances (missing 4 phthalates) or lacks a signed CoC. | Reel suffix or lot code on physical label does not match the PO or CoC. |
Compliance workflows break down when companies either expect warehouse receiving clerks to interpret European chemical law at the loading dock, or allow buyers to archive a PDF during RFQ without ever checking the physical termination suffix when parts arrive.
As emphasized in SiliconExpert's guide to RoHS and REACH compliance across the electronics lifecycle, effective verification separates Stage 1 (Engineering & RFQ Qualification) from Stage 2 (Incoming Quality Control at Receiving).
| Verification Stage | Field to Verify | Exact Requirement / Acceptance Criteria | Red Flag / Rejection Trigger |
|---|---|---|---|
| Stage 1: RFQ & Onboarding (Procurement & Compliance Engineering) | 1. Issuing Authority & Template Format | Issued on official OCM letterhead/portal (Panasonic example[6]) or executed on your mandatory customer compliance template with an authorized signature, title, and date. | Unsigned PDFs, distributor-typed generic letters for non-franchised stock, or informal self-made supplier letters missing required legal fields. |
| Stage 1: RFQ & Onboarding | 2. Exact Part Number / Series Mapping | Lists the full OCM Part Number including the RoHS/lead-free ordering suffix (e.g., -LF, PBF, G, E3), or a Series table that explicitly maps the suffix. |
Blanket series certificate where the series includes both leaded () and Pb-free variants without distinguishing the suffix. |
| Stage 1: RFQ & Onboarding | 3. RoHS Directive & 10-Substance Scope | Explicitly cites Directive 2011/65/EU and Delegated Directive (EU) 2015/863 (confirming all 10 substances at ≤0.1% w/w and Cd at ≤0.01% w/w in homogeneous materials). |
References withdrawn directives (2002/95/EC) or only covers the legacy 6 RoHS substances (omitting DEHP, BBP, DBP, DIBP). |
| Stage 1: RFQ & Onboarding | 4. RoHS Annex III / IV Exemption Code | Explicitly states "Compliant without exemptions" OR lists the exact Annex III/IV code (e.g., 6(c), 7(a), 7(c)-I) verified as active on EUR-Lex. |
States a bare "RoHS Compliant / Pass" for a high-temp solder diode or brass connector while hiding the underlying Annex III exemption. |
| Stage 1: RFQ & Onboarding | 5. REACH SVHC Candidate List Version | Cites Regulation (EC) No 1907/2006 Article 33 and states the exact ECHA Candidate List publication date evaluated at the individual article level (0.1% w/w). |
Undated "REACH Compliant" statement, or a certificate referencing an outdated ECHA Candidate List from previous years. |
| Stage 1: RFQ & Onboarding | 6. SVHC >0.1% w/w, Safe Use & SCIP Data | If any sub-article exceeds 0.1% w/w SVHC, provides substance name, CAS/EC number, concentration, Article Safe Usage Statements, and SCIP notification data[3]. |
Claims a lead RoHS exemption (e.g., 6(c) or 7(a)) while simultaneously claiming "0% SVHC / REACH Free". |
| Stage 2: Receiving / IQC (Warehouse & Quality Inspectors) | 7. Physical MPN & Pb-Free Suffix Match | The MPN and plating suffix printed on the physical OCM reel/tray/tube label match the Purchase Order, Packing List, and approved Stage 1 RoHS certificate. | Physical reel arrives with a standard/leaded suffix (or missing the -LF/PBF suffix) despite the PO specifying the RoHS-compliant part. |
| Stage 2: Receiving / IQC | 8. RoHS / Pb-Free Label Symbols | Moisture barrier bag (MBB) and inner reel label display OCM RoHS/Pb-Free markings (RoHS, Pb-Free, e3/e4 JEDEC code, and peak reflow temp). |
Missing environmental markings, tampered labels, or conflicting secondary labels placed over the original OCM bar code. |
| Stage 2: Receiving / IQC | 9. Lot / Batch & Date Code Continuity | Lot Number and Date Code on the physical reel match the shipment's Lot CoC and fall within the validity date of the declaration or IEC 62321 report. | Lot CoC omits batch numbers, or date codes predate the supplier's transition to phthalate-free (2015/863) materials. |
| Stage 2: Receiving / IQC | 10. Authorized Chain of Custody | Packing slip and CoC trace directly to the OCM or authorized distributor (DigiKey verification model). | Unverified broker invoice CoC with no OCM packing trace (escalate immediately to XRF screening). |
When procurement specialists search online for component compliance templates or read generic summaries, they often encounter conflicting advice. Understanding why industry sources appear to disagree—and knowing which red flags to reject immediately—protects your engineering team from audit failures.
7439-92-1, EC 231-100-4) is restricted under EU RoHS (0.1% homogeneous limit) and listed as an ECHA REACH Candidate List SVHC (>0.1% w/w article threshold). Many components are legally RoHS Compliant by Exemption under Annex III—such as Exemption 6(c) (copper/brass alloys containing up to 4% lead), Exemption 7(a) (high-melting-temperature solders containing ≥85% lead), or Exemption 7(c)-I (lead in glass or ceramic electronic components). Because the lead concentration in that brass pin, solder joint, or ceramic element exceeds 0.1% w/w of that sub-article, ECHA's Article 33 rules on substances in articles[1] require the supplier to declare Lead as a REACH SVHC above 0.1% w/w and provide Safe Use/SCIP data. Rule: If a supplier certificate claims RoHS Exemption 6(c), 7(a), or 7(c)-I while simultaneously checking "0% REACH SVHC," the document is legally contradictory and must be rejected.Red Flag 2: Legacy 6-Substance Lab Reports (Missing Phthalates)
Suppliers of cables, plastic housings, or fans occasionally submit older IEC 62321 laboratory reports that only test for the original six RoHS substances (Pb, Hg, Cd, , PBB, PBDE). Always verify that the lab report explicitly lists test results for all 10 substances, including the four phthalates (DEHP, BBP, DBP, DIBP) mandated under Delegated Directive (EU) 2015/863.
-Z or -LF lead-free packaging code, but your purchase order specifies a legacy suffix, the certificate does not cover your parts.Neither the European Chemicals Agency (ECHA) nor any EU government body issues an official "REACH certificate" or approval stamp. Instead, procurement teams demonstrate compliance by requesting a supplier's REACH Article 33 SVHC Declaration referencing the active ECHA Candidate List date, Article Safe Use instructions (if any SVHC exceeds 0.1% w/w), and a Full Material Disclosure (FMD).
Yes. Many tier-1 component manufacturers—such as Panasonic Industry[6]—issue combined RoHS and REACH confirmation reports by part number or product series. To pass an audit, a combined document must explicitly state the EU RoHS directive versions (2011/65/EU and (EU) 2015/863), any claimed Annex III/IV exemptions, and the exact ECHA SVHC Candidate List publication date.
No. First, REACH tracks an expanding Candidate List of SVHCs far beyond the 10 substances restricted by EU RoHS. Second, a component can be legally "RoHS compliant by exemption" (such as containing lead above 0.1% w/w in high-temperature solder or brass alloys under Annex III) while simultaneously triggering mandatory REACH Article 33 SVHC disclosure and SCIP notification.
Because ECHA typically updates the SVHC Candidate List twice a year, standalone pass/fail REACH declarations should be refreshed after each ECHA Candidate List update or whenever a Product Change Notification (PCN) alters component materials. Collecting a Full Material Disclosure (FMD) eliminates the need to re-survey suppliers after every semiannual ECHA update.
Before closing your next component onboarding ticket or releasing a shipment from receiving inspection, run through this final operational checklist:
≤0.1% w/w; Cd ≤0.01% w/w in homogeneous materials).6(c), 7(a), 7(c)-I) exceeding 0.1% w/w of the sub-article, ensure the REACH declaration properly lists Lead (7439-92-1) as an SVHC along with Safe Use instructions and SCIP data.Kynix was founded in 2008, specializing in the electronic components distribution business. We adhere to honesty and ethics as our business philosophy and have gradually established an excellent reputation and credibility in our international business. With the accurate quotation, excellent credit, reasonable price, reliable quality, fast delivery, and authentic service, we have won the praise of the majority of customers.
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