The 2018 revision to the Waste Framework Directive (WFD) requires the European Chemicals Agency (Echa) to establish the new Substances of Concern in Products (Scip) database by 5 January 2020. EU member states are required to transpose the WFD requirements into national laws by 5 July 2020.
Starting 5 January 2021, all companies in Europe will be required to report information into the new Scip database for any products which include articles that contain REACH Candidate List substances above 0.1%, with possible subsequent enforcement by member state regulatory authorities.
The reporting requirement applies to all layers in the supply chain, including the original article supplier, suppliers of sub-assemblies and assemblies that contain affected articles, suppliers of finished products that contain affected articles, and re-sellers and distributors who supply the finished product to retailers. Companies located outside Europe may be able to report their product information to the Scip database, for example on behalf of suppliers in Europe.
Under REACH, information submitted to Echa has to be in Iuclid format. Iuclid was developed by Echa in association with the OECD and is a software to record, store, maintain and exchange data on chemical substances. Iuclid 6.4 was published October 2019 and includes the data model to support Scip database submissions.
Echa will provide three options for companies to prepare and submit their data:
• Companies can manually prepare their submissions online, one product at a time, using Iuclid on the cloud. After creating their notification in Iuclid, the company then needs to upload it to the Echa submission portal for further processing.
• Companies can download Iuclid and install it in their own IT environment so that they can create Iuclid files offline locally on their computers. As above, the company then needs to upload the notifications to the Echa submission portal for further processing.
• Larger companies with a lot to submit will want to integrate their IT systems to the Scip database to create and submit Iuclid files automatically.
Every individual article is created as a separate Iuclid document which has its own unique identifier known as the Iuclid document key. The Iuclid document key is a random sequence of 36 hexadecimal characters, for example “1e991422-239c-4b49-8a42-3f4730aa51a0”. There is no relationship between the Iucid document key for one article at a supplier compared to another article at the same supplier.
Most products are “complex objects” which are assembled from several articles and/or component complex objects. The Iuclid document for a complex object is a tree-like structure which includes links to the article documents and/or component complex objects documents. This means that the Iuclid document for the supplier’s article or the supplier’s component complex object must be created so that the Iuclid document for company’s complex object can link to the supplier’s article or the supplier’s component complex object.
It may take several months to receive data across multiple layers in the supply chain. When suppliers pass on to the company their information about REACH candidate list substances in their articles, the company needs to collate this information and create the Iuclid documents for the suppliers’ articles and the suppliers’ complex objects.
In the meantime, new SVHCs are added to the REACH Candidate List every six months and so the company’s data may need to be updated every six months as suppliers report new SVHCs in new articles.
When suppliers pass on to the company their information about new REACH Candidate List substances in their new articles, the company will need to create Iuclid documents for suppliers’ new articles and update Iuclid documents for component complex objects so that the company can then update the Iuclid document for company’s complex object.
In view of this constantly changing supply chain data, using an IT system to manage supply chain data and submitting to the Echa portal using a system-to-system integration can be more efficient than updating data manually in a Iuclid cloud instance or an off-line Iuclid installation.
The IT system can build up the Iuclid documents for the supplier articles and complex objects as the company communicates requirements down the supply chain and receives data back up the supply chain across multiple layers of suppliers over many months. Supplier data will be received at different times and these data can be managed and stored centrally in the IT system.
When new SVHCs are added to the REACH Candidate List every six months and suppliers report new SVHCs in new articles, the IT system can create new Iuclid documents for new supplier articles and complex object components, or update Iuclid documents for existing supplier articles and component complex objects.
Article by: Aidan Turnbull Director BOMcheck.net