Steven Andrews: I would recommend caution with this sort of declaration. If a component or part is compliant by exemption, the declaration should reference the particular exemption(s). This is important because the use of the restricted substance is only allowed within the defined limits of the exemption at the “homogenous material” level. Referring to the particular exemption in the declaration also helps ensure the exemption has not been amended or deleted through a specific or generic “sunset” date. It is also important to note many exemptions are related to the end use of a product, therefore many would not be applicable to components, parts, or materials.