EU SCIP Database Requirements

The reporting obligations for manufacturers, importers and distributors to have submitted information about their products and first Articles that contains REACH Candidate List SVHCs starts on January 5, 2021. This new regulatory requirements will be a significant challenge for many industries, including automotive, aerospace, defense, heavy equipment, and electronics given that many of these products contain one or more SVHCs due to a lack of technical alternatives. The specifications include several new data requirements that supply chains do not typically report. The ECHA is developing the SCIP database and has said they expect to have it ready for formal submission by October 2020. For additional information on the SCIP, related articles are available on the ECD Compliance news blog.

Support for Supplier Data Declaration for EU SCIP Database

The revised IEC 62474 standard was developed to meet a variety of global regulations including emerging requirements under the EU REACH regulation and the EU Waste Framework Directive (WFD).  The EU Substances of Concern (SCIP) database was a focus area given that it would be a challenging requirement for manufacturers and suppliers. The updated IEC 62474 Data Exchange Format (DXF) (version X8.00 released in April 2019) included such features as the isArticle flag, support for safe use instructions, an identifier field, material classification (e.g. categories). The IEC 62474 Validation Team (VT62474) is finalizing a minor update to the Data Exchange to ensure effective support for the extra data fields for SCIP, especially the mandatory data fields.  The VT is doing this by adding generic data fields wherever possible so that they can be used for SCIP and other future regulations that may require similar information disclosure.  No changes are required in the IEC 62474 document; changes are only needed in the XML schema and the Developer’s Table which can both be updated using the expedited IEC database management process.

Publication of the update (which will be revision X8.10) is expected in February 2020.

Note: The VT62474 still needs to formally approve the updates to the data exchange format; some of the features described  below are already part of the X8.00, but some features should be considered preliminary until they are officially published on the IEC 62474 database.

SCIP Support in Composition Declaration and Declaration for Compliance

The declaration format now includes separate declaration modules for ‘compliance’ and ‘composition declaration’ – the Declaration for Compliance module was one of the new features added in IEC 62474:2018 (see Figure 1). Supply Chain communication for SCIP will be supported in both of these declaration modules.

Figure 1:  Material Declaration Hierarchy

Both the composition and compliance modules provide a flag (TRUE/FALSE) that enables the responder (the supplier) to indicate that the declaration includes the mandatory information needed for a downstream manufacturer to submit into the SCIP database.  For both declarations, the flag is named “isSCIPComplete”.