Today, manufacturers of complex products often find themselves in the middle of a volatile and branched supply chain. In this position, which may be hard to retrace, the reliable exchange of technical information is a challenge that becomes even more important with increasing regulatory pressure. Especially information on the substances contained and the associated safety risks for the environment and health has legal relevance and is subject to due diligence.
The duty of declaration is challenging backward and forward the supply chain
For supplier management addressing material compliance properly, this means that the declaration of substances should already be taken into account when selecting and qualifying suppliers.
In many cases, this requirement is jeopardised by the market power of the suppliers. Despite of the minimum requirements of the substance declaration are mostly being met, especially within the EU, the format is often left to the opinion of the supplier. The result is a high maintenance effort for the manufacturer using the supplier’s parts and a risk for the quality of his own declaration. Cooperative thinking and understanding of the different positions are required to solve this challenge constructively. Cross-industry platforms for the exchange of substance information between the stakeholders of a supply chain can be a valid solution in this case.
Especially within the EU, the social awareness for environmental protection and the legal requirements regarding EH&S are growing. Suppliers from non-EU countries sometimes find these regulations challenging to follow. For manufacturers within the EU this means a further challenge for their own declaration obligations. In order to reduce efforts in laboratory analyses of purchased parts to a minimum, an exchange of data with non-European suppliers is also necessary with regard to the substances they contain – but this requires acceptance of the suppliers and is possibly accompanied by higher prices for the purchased parts.
ECHA is continuously tightening the regulations on the substitution of substances harmful in terms of health and the environment. The number of substances on the REACH candidate list is being updated every six months. As a result, substances that can be used without concerns today may be SVHC tomorrow and will have to be declared . In order to be able to react quickly and at fair cost to these changing requirements, a technology-based exchange of information with suppliers is now almost inevitable.
To transmit substance information efficiently and sustainably in complex and globally branched supply chains, the following success factors should be kept in mind:
• Consideration of the knowhow and motivation of suppliers to declare already within the supplier selection
• Awareness of non-EU suppliers regarding EU requirements and acceptance of the associated declaration requirements
• Use of uniform exchange platforms for the transfer of substance information in the supply chain
• Transparency in your own supply chain and including of material compliance in purchasing processes
• Defined escalation processes in supplier management
The analysis of the current supply chain and the prioritised, step-by-step qualification aiming to a supplier management system capable of material compliance is a first step. We will be on your side and gladly and competently accompany you.