For the past 20 years, automotive companies have reported REACH Candidate List substances in articles into the International Material Database System (IMDS). Now they are faced with the prospect of needing to report similar information into the Substances of Concern in Products (SCIP) database beginning in 2021. Automotive companies shouldn’t have to reinvent the wheel for the new SCIP reporting requirements.
Unfortunately, the current version of IMDS does not support the electronic download of all SCIP data fields. Although those capabilities may be included with the release of IMDS 13.0, this update will not be ready until well after the January 5, 2021, SCIP reporting deadline. It is also not guaranteed that IMDS 13.0 will always be able to capture all relevant fields that would make SCIP reporting easier.
The IMDS to SCIP Data Transfer Blueprint
Tetra Tech compliance experts have worked together to build a comprehensive blueprint that maps the new SCIP data fields and associates them with the most relevant IMDS data fields. We have validated our approach by using IMDS data to successfully complete fully compliant SCIP dossiers that meet all business validation rules and can be submitted via the ECHA submission portal.
The key elements of this blueprint are outlined below, and more detailed information will be available after ECHA finalizes its SCIP data reporting fields in November 2020.
Using IMDS Data for SCIP Data Fields
IMDS data can be used to supply information for the required SCIP data fields. Table 1 itemizes these fields that can be used to satisfy SCIP requirements.
While not every entry in this table may be legally required for every EEA member state, it would be difficult to be fully SCIP compliant without capturing all of the information, which is readily available in IMDS.
TABLE 1 – Required and Corresponding Data Fields
|SCIP DATA REQUIREMENT
|CANDIDATE IMDS FIELD TO FULFILL REQUIREMENT
|Primary Article Identifier Value
|Number of Units
|Candidate List Substance Name
|Portion (indirectly inferred)
|Material Classification (indirectly inferred)
There is also data in IMDS that, although it is not required in SCIP, would strengthen your dossier by positioning it better for possible future customers and legal requirements. Table 2 itemizes IMDS fields that would be useful for SCIP reporting even if they are not required.
For example, the weight information is critical in order to clearly demonstrate that the SVHC threshold calculation was done correctly. And the IMDS ID Number may be useful to any automotive customers who want to cross-reference data between the two reporting databases.
It is, of course, possible to omit or conceal any of this information if it is confidential business information; if entered correctly, it can be hidden from the public.
TABLE 2 – Useful IMDS Data for Better SCIP Reporting
|USEFUL IMDS FIELD
|PURPOSE FOR CAPTURING IN SCIP
|Needed in order to support math for Concern Element concentration
|IMDS ID Number
|Traceability to source data
|Traceability to supplier
|Ability to link to LE User in ECHA Submission Portal
|May be same responsible party in IMDS as in SCIP for many companies
|Could prove important for waste management
Other SCIP Reporting Considerations for Automotive Companies
For automotive companies, there are other important considerations to keep in mind when doing SCIP reporting.
- Manufacturing location is not usually tracked in IMDS and may require some additional thought if your operations are global. If your part numbers are coded by region, you can electronically identify the parts that are manufactured in the EU through the logic built into your part numbering approach.
- Safe use instructions are not captured in IMDS but may be found in Safety Data Sheets (although unfortunately not often for articles).
- IMDS currently has limited ability to roll up SVHC information and evaluate it against the 0.1% threshold at the “Article-as-Such” level required by SCIP. Therefore, the math has to be performed on a case-by-case basis. Module 14 of our Online SCIP Training contains a video showing how this can be automated.
- New Candidate List substances and engineering changes to your components will require a change management process. You will need to establish a way of synchronizing your IMDS submission workflow with your SCIP reporting workflow. One action that will help in this process is to capture the IMDS ID Number in SCIP (see Table 2).
Meet Your SCIP Requirements Efficiently
The vision for IMDS reporting was that when new requirements emerged, the automotive supply chain would be prepared to address them with existing data. In 2021, SCIP will put this to the test, as the automotive industry should have an advantage in SCIP reporting with all of the data that has already been collected in IMDS.
Now is the time to prepare your roadmap for transitioning that data to meet SCIP requirements. Make your reporting efficient and avoid redundancies that could occur if you were to overlook the data you already have available at your fingertips.
For more detailed instructions and guidance on how to successfully transfer IMDS data to the SCIP database, take our Online SCIP Training. The full details of the IMDS to SCIP blueprint is covered in Module Fourteen: Industry-Specific Application for Automotive – SCIP and IMDS/GADSL.
For further support, contact Tetra Tech at [email protected]. We can support you as you prepare to meet SCIP requirements so you can report with confidence.