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echa:introduction

European Chemical Agency

The ECHA is an agency of the European Union, and it is the authors and managers of the Substances of Concern in articles as such or in complex objects (SCIP). The text on its web states that this is established under the Waste Framework Directive (WFD) so there is more to SCIP than just itself.

Please note: all that follows should be concerned a draft, and some of it are my own assumptions.

First, there is a 05JAN2021 deadline to SCIP, so it is relevant today and it is going to stay that way.
Next, the Substances of Very High Concern (SVHC) which is part of the WFD is already in effect.

Finally, the purpose of WFD is realized by the published and updated list of substances regarding environmental protection (SVHC), and now with the concept called “circular economy” (SCIP).

This is from their web:

The SCIP database has three main objectives:

  • Decrease the generation of waste containing hazardous substances by supporting the substitution of substances of concern in articles placed on the EU market.
  • Make information available to further improve waste treatment operations.
  • Allow authorities to monitor the use of substances of concern in articles and initiate appropriate actions over the whole lifecycle of articles, including at their waste stage.

The SCIP database complements the existing communication and notification obligations for Candidate List substances in articles under REACH.

It seems that SCIP is relevant only for articles incompatible with SVHC.

The burden of proof remains with the SVHC, and the SCIP might solve the issue with BOMs that use multi-manufacturer AVLs. For example: Assy A, using MFG B, C, D where D fails SVHC. All these are only my own assumptions though.

Standards

Here we describe relevant resources such as Standards Organizations, Industry Publications. Some of these are involved and extensive enough to have a dedicated wiki. We do not publish links here, as keeping them up to date is beyond my capacity. As FourOh-LLC grows that could be one of our value-adding function.

BOMcheck

This is a proprietary supply chain management network, closely working with all EU regulatory agencies. Unless your customer requires you to declare via BOMcheck this is not something you are going to use.

SiliconExpert

They do SVHC updates, but not yet have anything documented about SCIP. However, SiliconExpert is a primary source of information for SVHC and predictably it is going to be the same for SCIP.

IPC

They publish the “IPC-175x” family of “Material Declaration Exchange Standards” in PDF, and implemented in XML. They stopped implementing in Adobe PDF Forms - the PDF is now describes, like some academic text, the XML Standard. In turn the XML Standard is implemented by “Solution Providers” like BOMcheck and SiliconExpert.

CAS Registry

These are the people who everything there is to know about elements, alloys, polymers and all other types of substances.

Sources

The optimal way to track the compliance status is by an automated process. The “Full Material Declaration (FMD)” or “Ingredient List” is compared to the SVHC List. The list contains “CAS Registry Numbers”, effective dates, concentration limits, and exemptions.

Details of the Declaration depends on the implementation - some like BOMcheck is proprietary, others are read-only subscriptions, full-service contractual, etc. All data going in is already in copyright, trademark and protected. Your customer is going to decide what percentage of the in-going data may be unknown, kept as Trade Secret.

The FMD is static - once the article with the Manufacturer Part Number (MPN) is on the market the FMD is not going to change. Still, the SVHC list grows every 6 months, knocking more and more MPNs off the Compliant lists.

Your final assemblies might be serialized - but you probably not tracking the MPNs across the entire AVL, for every Batch or Order. This means that some or most of your final assemblies sold in 2016 were fully compliant: if you scrub the same BOM today they might be 10, 20, 50, 100 percent non-compliant.

Conclusion

ECHA is just a fraction of the environmental regulation industry. Others are more familiar to most people, and those include RoHS and REACH. In fact it is better to find and follow a third-party expert such as RoHS Guide until you become comfortable with the new concepts. Navigating the humangous EU web is a full-time, life-time job and its better left to the experts.

Storing this sort of data in SQL or XML is something FourOh-LLC could pilot for you. Engaging a full-service compliance agent costs up to a 100k USD or more. Before you spend that kind of money its always worth to spend a few hundred (or whatever you pay for your employee), and a few extra days, to narrow what you need.

echa/introduction.txt · Last modified: 2020/02/13 15:14 by admin2welcome