The European Chemicals Agency (ECHA) has published the data format that manufacturers and importers will use to submit information into the European SCIP (Substance of Concern in Products) Database. The format is important to manufacturers because it provides details about the information that they need to collect from their supply base in order to make their submissions into the database. A good understanding of what data should be requested from suppliers is crucial – to avoid multiple requests to suppliers and also to avoid overburdening them for information that isn’t necessary.
Background on SCIP
The mandate for SCIP comes from Directive (EU) 2018/851 revising the EU Waste Framework Directive (WFD). It requires ECHA to develop and operate the database and directs EU Member States to transpose the Directive into regulations that require manufacturers, importers, and distributors (the duty holders) to submit information about products into the database. The information needs to be submitted if the product is placed on the EU market and if it contains one or more REACH Candidate List substance(s) as per REACH Article 33. The WFD has set the start date as from January 5, 2021.
Timeline for Developing and Deploying SCIP
During the SCIP workshop held on November 12 in Helsinki, ECHA indicated that they expect to have a prototype database available for testing by the end of January 2020, and the production database available for duty holders to start fulfilling their submission obligations in October 2020.
The Data Format and it’s Importance to Manufacturers
The SCIP data format is implemented as a series of XML schemas and picklists (drop down lists) as part of the ECHA IUCLID 6.4 software release. This supplements the “Detailed Information Requirements for the SCIP Database” that ECHA published in September 2019.
The data format provides insight into what information is needed – whether a specific data element is a single value or multiple data fields such as a data type and a data value. The communication of a data type is sometimes necessary for downstream manufacturers to interpret the data value and it may be needed for SCIP. The data format may also specify whether data is free text, needs to conform to a specific format or if there are limited options such as from a picklist.
If data is received from a supplier as free text but needs to be mapped into a picklist, this can be a challenge for the downstream manufacturer – resulting in extra work and/or quality issues.
Free text is notoriously error prone for automated processing given that something as simple as an extra space, a missing space or a spelling error results in a mismatch for computer software, sometimes requiring manual review. ECHA indicated during the workshop that all submissions will undergo an automated validation to ensure that they meet the requirements.
Many of the SCIP data elements are implemented as a set of data. One example is the Primary Article Identifier – it includes the data elements Primary Article Identifier Type and Primary Article Identifier Value. Primary Article Identifier Type, in turn, provides a picklist of options and a free text string in the event that the supplier selected ‘other’. A manufacturer that receives an article identifier value but no information as to whether it represents an EAN, GTIN, GPC, etc. will be in a difficult position to interpret the data and to make a meaningful submission into the SCIP database. The primary article identifier is particularly important given that the combination of this value with the submitter entity code provides the SCIP index to be able to update the article data in the future.
Obtaining the correct information from suppliers improves data quality and reduces effort and risk compared to mapping the data afterwards.
The XML schema for ARTICLE as published by ECHA gives us a good indication of the data needed for submission. The schema bundles the information into data groups for: Identifiers, Categorization, Characteristics, Safe Use Instructions, Complex Object Components, and Concern Elements. Each data group contains multiple data fields. The Concern Element contains information about the version of the Candidate List that was used in the product assessment, the Candidate List substance in the article, and the type of material/mixture containing the substance.
ECHA plans to use picklists for many of the data fields – this improves data quality but means that manufacturers and importers will need to map data from suppliers to one of the specific picklist entries provided by ECHA. Data fields using picklists include:
- Primary article identifier (Type) (e.g. EAN, GPC, GTIN, with option to specify other)
- Other article identifier (Type) (e.g. EAN, GPC, GTIN, with option to specify other)
- Other names (Type) (e.g. brand, model, type, with option to specify other)
- Article categories (i.e. CN codes)
- Produced in European Union
- Unit of measure for characteristics
- Candidate List Version
- Concentration range
- Material category
- Additional material characteristics
- Mixture category
- Language of disassembly instructions
Another benefit of using picklists is the ease of making information available in all European languages without extra effort from the duty holder. Each entry in a picklist is represented by a numerical identifier that is then stored in the SCIP database. When a user accesses the database, that numerical identifier can be mapped to text in the language that’s most appropriate for the user.
Submitting into the SCIP Database
During the SCIP Workshop, ECHA described three ways for duty holders to submit their article and SVHC information: online submission via a web-based user interface; offline using the ECHA IUCLID tool; and system to system for bulk uploads.
Protecting Supply Chain Confidentiality
There are link elements in the format allowing a complex object to link to a supplier’s part (complex object or article as such) that has already been submitted into the SCIP database. To avoid revealing the supplier of the part (which is typically considered confidential information), ECHA has segregated the Article information from the Submitter information. When a user accesses the information about the complex object, they will see the article name and substance content of the supplier’s article. However, the information about the submitter (the supplier) and certain data fields that could reveal supplier specific information will not be visible. But ECHA emphasized that it will be up to submitters to ensure that they do not enter confidential information into data fields that are visible to users.
Moving Forward – Collecting Supply Chain Data
Several industry associations and standards development groups have been working with ECHA to provide input on the nature of global supply chains, complexity of BOMS, concerns about confidential information, and information available from material declarations to help guide SCIP implementation to be practical and achievable. Some of the recommendations have been accepted; others have not and may represent submission challenges for industry and data quality challenges for ECHA and European users of the database.
In the meantime, all manufacturers with products that potentially contain REACH Candidate List substances need to start preparing their supply base for the additional information needs. The time that remains before manufacturer obligations take effect is minimal given the task. Eliminating SVHCs from products is ideal, but there are products and applications for which this is not yet technically feasible – including many electronic products.
Material Declaration Standards to Support SCIP
Several industry standards on material declaration are currently being updated to support SCIP. Some of these were developed with REACH in mind and already support 95% of the mandatory requirements; they are getting minor updates to ensure that all data needed from the supply chain to support manufacturers with mandatory SCIP information is available. These updated standards will be published starting early 2020. Some solution providers are also preparing their systems to collect the additional data for SCIP and to support the updated material declaration standards as quickly as possible.
The ARTICLE XML schema is included as part of the latest release of the ECHA IUCLID data format (IUCLID 6.4) on the ECHA IUCLID website (https://iuclid6.echa.europa.eu/format).
Interested in learning more about the SCIP database? Register for our free webinar here.