This is the third in a series of articles on how to use IEC 62474 for collecting supply chain information to meet the emerging EU SCIP data information requirements.

This article was updated  based on adjustments made by VT62474 at its January 29-31, 2020 meeting.

SCIP Reporting in the Composition Declaration

The Composition Declaration is one of two substance declaration modules provided by IEC 62474:2018. It is used by a response (e.g. supplier) to provide a hierarchical declaration of substances within materials and/or product parts that make up the product.  IEC 62474 requires that at least DSL substances that are present in the product be reported in a composition declaration, but it may include other substances, up to and including a full material declaration (FMD).

The declaration of materials and product parts is usually optional, but this becomes mandatory if the material or product part contains a declarable substance based on that material or product part.  For example, if the declarable substance has a threshold based on battery then the battery must be declared as a product part.  This also applies to a (REACH) article that contains an SVHC on the REACH Candidate List.  The first article containing the SVHC must be declared as a product part so that downstream manufacturers can calculate the mass percent of the SVHC in the Article.

Note: Although the standard specifies that material and product parts are usually optional, a requester (e.g. manufacturer or a solution provider) may require that material and/or product part information be provided, even though the standard does not make it mandatory. That is, requester requirements may supplement and enhance the minimum requirements specified in the standard, but this information is subject to mutual agreement between requester and responder.

Article containing the REACH SVHC is reported as a ProductPart

For EU SCIP submissions, the manufacturer/importer needs to submit (1) information about the product being imported or manufactured and (2) information about the lowest-level article in the build hierarchy where the SVHC is included — this is referred to as the “declarable article”.  This declarable article may be an “article as such” (e.g. a simple fastener such as a screw) or it may be a “complex object” (e.g.  a power supply). Each SVHC in the product will have a declarable article that is used to calculate its concentration.

If product is the declarable article, then the SVHC is reported as a Substance directly under the Product.  However, if the declarable article is a part or subpart in the product, this article needs to be declared as a ProductPart in the composition declaration.  ProductPart includes ProductID (as described above) which identifies the mandatory information about the declarable article including the Article name, primary article identifier, article category (i.e. CN customs code). The countryOfManufacture field may be used (if reported) to determine production in the EU information.

The ProductPart element itself also includes the isArticle flag and a data field for numberOfUnits which is used to report how many of these articles are present in the product as required for SCIP submission.

ProductPart also allows attachments. This was primary intended for test reports or other conformance documentation, but it may be used to attach pictures or disassembly instructions which are optional pieces of information suggested by ECHA for SCIP submissions.

Information about the Material

Some of the information required for the SCIP submission is reported in the Material element of the IEC 62474 Composition Declaration.  The figure below illustrates the data fields that provide information needed for SCIP submission.

SCIP requires that either a material category or a mixture category associated with the SVHC be reported.  MaterialClassID is used to indicate the Material Category (the ListID will indicate the ECHA material category list). A new UseDescriptor element has been added and may be used to indicate the mixture category.  In November 2019, ECHA indicated that reporting of material properties will be optional, but if desired, the supplier may report these in the newly added data field for MaterialProperty.

If the REACH Candidate List entry is a substance group, then the declarable substance group in the DSL should be reported using the DsgID data field.

SCIP Data requirements for Composition Declaration

As noted earlier, the Composition Declaration includes a isSCIPComplete flag that allows the supplier to indicate if all of the necessary information for SCIP has been provided. The definition and detailed requirements are provided in the IEC 62474 Developer’s Table.

The supplier may set isSCIPComplete = TRUE 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 Composition Declaration:

When a DS or DSG Substance that is on the REACH Candidate List is present above the reporting threshold:

• the declarable article shall be declared as a ProductPart meeting the following requirements:
  • the isArticle flag is declared and set TRUE
  • ProductID name provides the “Article name”;
  • ProductID ProductCategory provides the ArticleCategory information
  • ProductID IdentifierCode provides at least one Article Identifier (as specified in the SCIP requirements specification). Note: The first IdentifierCode provided for the ProductPart will be considered the Primary Article Identifier.
  • ProductPart includes at least one Safe Use instruction (either free text or from a SafeUse list) using the SafeUse element
• The Material containing the substance within the declarable article is declared. The Material element reports the: ECHA SCIP material category (MaterialClassID is used) and/or the mixture category (UseDescriptor is used).

Data fields shall meet the information requirements as specified in the ECHA “Detailed information requirements for the SIP database”.

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 these details 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.