ECHA is moving towards using the Substances of Concern in articles or in complex objects [Products] database (SCIP) to regulate the gathering of information regarding hazardous materials, but the automotive industry already has a system in place to do the same thing: International Material Database System (IMDS).
Will this help the automotive industry be more prepared to comply with the SCIP?
IMDS and IDIS
Under the End of Life Vehicles (ELV) Directive, vehicle manufacturers are already required to restrict the use of hazardous materials in new vehicles and meet certain targets for re-use, recycling and recovery when their vehicles become waste. When the ELV Directive entered into force in 2000, the automotive industry decided that the best way to comply with the directive was to develop a centralized system to gather materials data from their supply chain.
The result was IMDS, the system that is still used today to enable the automotive industry to gather materials data from all tiers of the supply chain for all parts used in the vehicle. This is used to comply with the ELV heavy metals restrictions in new vehicles and also to provide reuse, recycling, and recoverability data in order to demonstrate that the vehicle can be processed at end of life within the stipulated legal targets (currently 95% by mass, 10% of which can be energy recovery).
Data gathered by IMDS is also used in part to populate the International Dismantling Information System (IDIS), which is used by recyclers to help in the processing of scrap vehicles. For example, by using the IDIS system to gather information about hazardous materials, recyclers can remove fluids and parts containing hazardous substances (e.g., batteries) as a first treatment step and therefore reduce any contamination of recycled materials during subsequent steps such as shredding.
But all of this has come at a considerable cost. The European Automobile Manufacturers Association — ACEA estimates that the industry has invested 10 billion EUR to date in the development of IMDS data collection efforts.
Because automotive manufacturers cannot sign off on their Production Parts Approval Process (PPAP) or place parts into production without IMDS, they have strong incentive to meet the IMDS data requirement at each tier of the supply chain. As a result, this data collection has become deeply ingrained into every part of the automotive business processes, and because the automotive supply chain is global, so is the IMDS user community. There are over 100,000 company IMDS accounts and around 300,000 users worldwide.
SCIP in Comparison
At first glance, the SCIP is similar to IMDS and IDIS in many ways:
- Like the SCIP, IMDS captures data from all tiers of the supply chain. In fact, IMDS goes one step further, as it also includes material producers in scope.
- Like the SCIP, IMDS captures the complete Bill of Materials (BoM) of parts and assemblies, but does so to include hierarchy and quantities rather like the linked article and number of units required by the SCIP.
- IMDS captures the substance within a material using percentages rather than the concentration ranges required by the SCIP.
- IDIS provides recyclers with information on the treatment of the product at end of life, including the presence of hazardous substances.
But there are some crucial differences when comparing the SCIP with IMDS and IDIS:
- In IMDS data is kept highly confidential whereas the SCIP is a publicly searchable system that includes not just individual parts but product structures and supply chain details.
- IMDS does not contain the complete vehicle BoMs, but rather includes only the top-level parts from a given vehicle BoM. The complete vehicle BoM remains in the vehicle manufacturer’s in-house system. In order to comply with the SCIP, the vehicle manufacturer would have to export that BoM into the SCIP. This would not be the “150% BoM” that is analysed for type approval of a given vehicle platform — a conglomerate of all variants — but rather would be BoM generated for each model variant, potentially at the VIN level.
- IMDS is not constrained by the boundaries of the EU. IMDS is not a legal requirement, rather it is a business to business agreement embedded into automotive business processes such as the Production Parts Approval Process (PPAP). The automotive supply chain is global, and so is the user base of IMDS. The SCIP will be a legal requirement in the EU, but will not be legally enforceable outside the EU. Importers of articles into the EU will have to rely on their non-EU supply chain to provide them with the data they need to comply with the SCIP data requirements, which could be extremely challenging given the level of detail required.
Other Concerns About the Usefulness of SCIP
There are also some more general concerns about the usefulness of the SCIP to its target users (the waste operators and consumers). The European Recycling Industries Confederation (EuRIC) position paper on the WFD Database points out that many articles reach the waste phase many years after being placed on the market (e.g. 15-20 years for cars, much longer for aircraft).
By the time those articles reach end of life, the data in the SCIP database would likely be out of date.; it would not contain information about the REACH Candidate List that is current at that time of recycling, but rather would include only what was current when the product was last placed on the market.
EuRIC also makes the point that the data in the database may be overwhelming. Complex objects such as cars and aircraft contain hundreds of thousands of components. Knowing that there is an SVHC in the jacket of a resistor on a printed circuit board found in a particular model variant, for example, is irrelevant to end users, even assuming that the component was not repaired or replaced during that product’s lifetime. As recycling processes are highly automated and applied to product categories rather than individual products, having such detailed information on the potentially thousands of parts of individual products would not add value to those processes.
Consumers similarly would be overwhelmed by the level of detail. A vehicle, for example, would likely comprise many hundreds of pages of documentation, rendering it impractical for the general consumer. And beyond that, many consumers do not have the level of in-depth knowledge to understand substances and their effects without further research.
Despite numerous rounds of engagement between ECHA and automotive industry stakeholders, there remain significant concerns as to how the industry can meet the requirements of the SCIP. ACEA have expressed concern to the European Commission that the automotive industry’s investment in IMDS and IDIS will be undermined by the SCIP database, viewing it as a parallel database duplicating workstreams and data already in place at great cost.
Earlier this year the Chemicals-Articles-Waste Cross Industry Platform ran a workshop to discuss the WFD DB information requirements. Following this event, they issued a Letter of Very High Concern to the EU Commission summarising the problematic issues and calling instead for a waste stream approach (i.e., rather than using a one-size-fits-all database) built on existing systems and infrastructure already developed and present in different industries.
In the case of the automotive industry, this could be achieved by adapting IMDS and IDIS. For example, adding a requirement for more information on the SVHC content of automotive materials and potentially other substances of interest such as critical raw materials. This would increase transparency about SVHCs in the same spirit as the SCIP, without dismantling reporting requirements the industry is already accustomed to. Such information could be aggregated to a level that would better equip recyclers to handle materials and components safely and minimise hazardous substance content in secondary materials.
There are also calls for the development of the SCIP to be halted until the EC Feasibility Study “on the use of comprehensive tools to manage information flows from product supply chains to waste” is finalised. Controversially, plans for the SCIP database were approved without a formal impact assessment.
There is no doubt that there is a need to realise a more circular economy, and industry is supportive of this objective. But it seems that the ‘one-size-fits-all’ approach of the SCIP database has many shortcomings and may be impossible to implement or enforce in its current guise. Industries are instead advocating a more tailored, industry specific approach that can leverage processes in place. It remains to be seen however if the European Commission is willing to change course.
For support in preparing for future materials database requirements — and how your current IMDS data can be leveraged for future requirements, contact our REACH experts.