This article was updated based on changes made by VT62474 at its January 29-31, 2020 meeting.
This is the fourth in a series of articles on how to use IEC 62474 for collecting supply chain information to meet the upcoming EU SCIP data information requirements.
The Declaration for Compliance is a true/false declaration against each entry in a Declarable Substance List (DSL), indicating whether the declarable substance (DS) or declarable substance group (DSG) is present in the product. This is similar to a Class C declaration in IPC-1752A. The Declaration for Compliance does not include information on product build hierarchy, but it includes sufficient information for the downstream manufacturer to be able to assess compliance against the regulations covered by the DSL.
Given that the Declaration for Compliance is intended to be a simple, product-level declaration, it’s not a natural mechanism to declare information about the articles containing SVHCs. Never-the-less, Compliance Declarations are preferred by some organizations, so the data exchange format for the Compliance module is being expanded to support information needed for SCIP submissions.
Declaring REACH SVHCs in a Declaration for Compliance
In a typical Compliance Declaration if a Candidate List SVHC is present in the product above 0.1 mass%, the responder (supplier) is required to declare that the SVHC is above threshold and to report the highest mass% within any of the first articles containing the SVHC and the total mass of the SVHC in the product. However, for SCIP submissions, information (such as article name, primary article identifier, etc) is needed for each different type of article containing the SVHC. For example, a product that contains the SVHC lead (Pb) in ten different articles within the product, needs ten sets of article information to be provided with the SVHC. Given that this is a unique requirement among regulations, a new “ProductPartInformation” element was created to support suppliers when declaring SCIP information in a Declaration for Compliance.
In a material declaration using Declaration for Compliance, the Product element (described above) already includes information about the top-level product. The Compliance element includes the DSL (which may be used to identify the Candidate list version), the the DSL entry (DsDsgID which identifies a specific SVHC entry), whether or not the SVHC is present above threshold, and if so, mass information. The isSCIPComplete flag was added so that the supplier can inform their downstream customers if the necessary information for SCIP has been declared. “ProductPartInformation” was added to the Data Exchange Format to provide the necessary information for each declarable article containing the SVHC.
Information about Declarable Articles in ProductPartInformation
The data structure for the new ProductPartInformation element is illustrated in the figure below. A sub-element “IntermediateComplexObject” may be used if the supplier wishes to provide additional information about an intermediate complex object in the build hierarchy, but this currently optional information in the SCIP database. For example, in the car example in the ECHA SCIP information requirements documents, this field may be used to identify information about the engine, which in turn contains the O-rings containing the SVHC. This field is optional.
SCIP Complete Declaration for Compliance
The Declaration for Compliance includes a isSCIPComplete flag that allows the supplierto indicate if all of the mandatory information has been provided for SCIP. The definition and detailed requirements are provided in the Developer’s Table. The isSCIPComplete flag may only be used if the DSL includes REACH Candidate List SVHCs (as applicable to the industry).
isSCIPComplete may be set TRUE by the responder if the following information is included in the declaration:
- For the Product element:
- ProductID name provides the “Article name”
- ProductID ProductCategory provides the ArticleCategory information
- ProductID IdentifierCode provides at least one Article Identifier (the first Identifier Code provided in the declaration file for the product will be considered the Primary Article Identifier)
- For Compliance, each DsDsg corresponding to a REACH Candidate List entry that is present in the product above the reporting threshold shall include ProductPartInformation for each declarable article containing the DsDsg. If the same Article occurs multiple times in the product, the numberOfInstances data field should be used instead of repeating ProductPartInformation multiple times.
- ProductPartInformation shall include (at a minimum): a link to the Article if already submitted in the SCIP database or the following information: article Category (as ProductCategory), at least one instance of ArticleIdentifier (as Identifier), numberOfInstances, at least one instance of SafeUse, at least one of MaterialCategory (as MaterialClassID) or MixtureCategory (as UseDescriptor).
Data fields shall meet the information requirements as specified in the ECHA “Detailed information requirements for the SIP database”.
The isSCIPComplete flag shall be used only if the DSL includes REACH Candidate List SVHCs (as applicable to the industry).
The descriptions and explanations above have supporting details in the IEC 62474 document and data exchange format that need to be met. Please refer to the official document to ensure that material declarations conform to IEC 62474.
Technical Support on IEC 62474
ECD Compliance provides consulting support and training to manufacturers, suppliers and solution providers on the emerging capabilities of IEC 62474 and the supply chain requirements for the EU SCIP database. Contact ECD Compliance for additional information.