The declaration of substances of concern to downstream users has been common practice at least since the REACH Regulation became mandatory. Safety data sheets, safety instructions on delivery notes or the exchange of information via databases are among the numerous means of communication used to fulfil the legal declaration obligations .
Within the Waste Framework Directive (WFD), it was decided to establish a central database into which products with declarable components must be entered in future . Especially manufacturers with a wide product portfolio and a large range of variants are adressed to implement stronger discipline and systematic approaches in order to collect and process the declarations of purchased parts.
In contrast to the high-volume business, the declaration into the SCIP database is not a sporadic duty in this case, but needs to be repeated in extreme cases for each delivered product, depending on the batch size. The manual analysis of the substances contained in the product on the basis of safety data sheets, delivery bills, laboratory results or other certificates from the suppliers will lead to effort that can hardly be managed with available resources .
Due to legal requirements, however, there is no workaround for this process. Especially in that situation an automated and stringent processes can help to optimise the effort for beein compliant. An essential goal for sustainable and efficient material compliance must therefore be a systematic approach to the identification of substances contained in the product.
IT-based platforms for data exchange between the parties in a supply chain are an already used option for larger companies in particular to integrate the subbliers substance information seamless into their own material management in standardised formats. With this option, manual efforts for substance declaration can be significantly reduced.
To retrieve and process the substance information from these external databases, the focus must be set on the data quality in the own material management. The most detailed substance information from suppliers is worthless if it cannot be retrieved from the database due to missing or incorrect identifiers.
Keeping the sunset-date of January 2021 in mind, by which the new declaration duty will start, manufacturers need to check the complexity of their own product portfolio regarding declaration. On this basis it can be easier examined to what extent it makes sense to automate the recording of substance information from suppliers in their own material management.
Does this affect your business? We are happy to offer our support for this assessment and the evaluation of the appropriate tools for your business