REGULATION & COMPLIANCE
of articles . That , however , can be costly and time-consuming .
There are no formal requirements on methods and laboratories to be used . We recommend that each company should evaluate and use appropriate methods , taking into consideration that , whenever possible , the existing standard analysis methods conducted in accredited laboratories are used . This approach is surely valid and applicable for EU-based suppliers as well . Additionally , in the case of EU-based suppliers , it is also possible to appeal to legal duties and obligations .
Storing data on SVHCs
It has become good practice for EUbased companies to actively request information on SVHC substances , communicate this information in the supply chain and report it to ECHA . However , the process does not end with reporting to SCIP and getting assigned a SCIP notification number .
Collecting the data and reporting to ECHA makes information on SVHCs in articles available throughout their whole lifecycle up to the waste stage . Knowing your products and materials will also contribute to efforts to replace Candidate List substances with safer alternatives once they are available , thus , in the long term , leading to a reduction in the number of those substances used in articles .
Collecting the data for further reporting to the SCIP database is not the only duty companies face or will face . Multiple legal requirements are coming from current regulations , and more are coming in the future . Information collection on PFAS or carbon footprint calculation , for example , will soon become a daily routine . Likewise , the implementation of a digital product passport concept , containing , inter alia , information
on chemicals present in products , has been discussed for quite some time already .
There is an aim to achieve full information accessibility with no information gaps when it comes to knowing what articles all around us contain and how to make them safer for us , our surroundings and the environment by eliminating SVHCs once a less dangerous alternative is available or disposing of them safely .
Within every single company , having an internal registry of substances and materials used – for distribution , manufacturing , assembling of articles , or any other uses , is crucial to keep the data consistent and abreast of constantly increasing numbers of regulatory requirements . Data collected on Candidate List substances can be built into an already existing system or be a starting point for those entities at the beginning of their way to compliance .
After a good system is set , additional data can be stored without any need to recreate or build a new registry . All the data on each article would be stored in one place . This can also be beneficial for the risk assessment of new parts and materials , allowing us to estimate quantities and identify SVHCs potentially contained in similar articles . It would make a company with such a registry a great business partner , able to communicate information on
chemicals in a fast and effective way .
Conclusion
Data collection and processing , as well as the grouping of articles for SCIP notification , communicating the results in the supply chain and keeping all records up to date , may be time-consuming and even frustrating if the processes are not set in an optimal way . We are confident , however , that it is worth investing time and energy to plan and systematise the data properly and stick with the chosen strategy . Now is certainly a good time to engage in it if you have not yet .
In our experience , many companies , from big corporations to SMEs are already on their trail , aware of SCIP reporting obligations , have data available and continue to collect and communicate it . It is crucial to face the future , where the collection of data on chemicals ( not only SVHCs ) will become more consistent and quite routine , saving much time – thanks to the efforts invested today . ●
Yana Trubitsyna
REGULATORY QUEEN
REGARTIS k + 420 731 706 391 J yana @ regartis . com j www . regartis . com
52 SPECIALITY CHEMICALS MAGAZINE ESTABLISHED 1981