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Introduction
Initiated by the Waste Framework Directive, the European Chemicals Agency (ECHA) introduced the SCIP database. The meaning of this acronym is: Substances of Concern In articles as such or in complex objects (Products).
More details about SCIP you will find directly at ECHA: SCIP database by ECHA
In short and using my words: for all products you place into the EU market that contain a substance to declare (to be more precise: a substance that is listed on the REACH candidate list and that is called Substance of Very High Concern where you are above the threshold for declaration [0.1%]) you are obliged to submit information about the product and the contained substances above threshold to ECHA using SCIP database.
The deadline for submitting your data to ECHA is 5th January 2021.
Just keep in mind, the candidate list of these substances to declare is not fix, the list is updated every six months by ECHA.
You have more than a few products that contain substances to be declared (SVHC)? Then the manual input interface of ECHA will for sure not suit you.
SAP Product Compliance
The first step for you to cope with the situation is the SAP product SAP Product Compliance.
- This software is either available as AddOn to ECC "SAP EHS Management Component Extension 6.0" with current support package level 06 or
- Fully embedded into S/4HANA as Product Compliance for Discrete Industries.
If you know this smart tool already, skip this chapter. Otherwise the short introduction might help you out.
From my point of view there are five important stacks I want to shed some light onto:
BOM Transfer
The compliance tool is not changing logistic objects as materials or bills of materials. Rather the compliance tool has its "own" objects, called Compliance Data Objects (CDO), they go far beyond the logistic information. But it heavily rely on the logistic data and the system needs to populate the compliance area with data, therefore the BOM Transfer is in place.
Using only the relevant bills of materials from SAP, this transfer creates the product structures in compliance area. These structures contain products, sub-assemblies, components and supplier-parts (separate compliance data object for each supplier of the component). You can transfer them manually or use the workflow-based transfer that updates the structures automatically.
Supplier Collaboration
In case you know your used basic materials, you can directly add the basic materials including all substances (full material declaration) to the component. Often this is not the case; therefore, you need to ask your suppliers for compliance statements of their products, your components. For collecting the data there are several possibilities:
- The supplier sends you the compliance data as PDF and you maintain the declarations manually in the system. That works well, but is time consuming.
- The supplier sends you compliance data using IPC-1752A files. SAP Product Compliance offers a guided procedure to bring the compliance data into the system.
- You work in automotive, then a standard interface using the IMDS Advanced Interface is in place to both import MDS data from your suppliers and send MDS out of your system to your customers in IMDS.
- You are not in automotive but want to benefit from compliance data exchange. Then use the SAP Consulting Solution to connect to CDX (CDX System) from partner DXC to exchange compliance data (requesting data and importing them to Product Compliance).
With the collected compliance data of your components, you are enabled to check the compliance of your products!
Compliance Requirements
Most of the compliance requirements that you can assign to your products relate to regulatory lists as ROHS, REACH-SVHC, California Proposition 65, etc. Regulatory lists are master data, so you can either maintain them manually or you can use the SAP Consulting Solution to connect to CDX to initially load and update these lists into Product Compliance. Having these lists in place, you can assign the relevant ones to your product and check the compliance status of the product. The system calculates the status for your product based on the component data and for e.g. REACH-SVHC the system considers the O5A-rule (Once An Article Always An Article) and sums up all contained declarable substances.
Change Processing Support
The system supports you with two powerful tools:
- ACP: Automatic Change Processing
- RCP: Regulatory Change Processing
ACP detects relevant changes to your compliance data and starts automatically a recalculation of the compliance status for the affected item and for all elements where it is contained.
RCP is triggered by a change of a released regulatory list or the release of a new revision and creates a worklist for you, containing all affected parts.
Compliance Analysis
Using the Core Data Service (CDS) views that works best with HANA DB, the system offers you a fast and convenient way to find and access items with issues. The screenshot below shows you for the selected Compliance Requirement "REACH-SVHC", the selected Compliance Status "Duty-To-Declare" and the selected supplier "SAP Fantasy Supplier".
Screenshot Compliance Analysis in SAP S/4HANA Product Compliance for Discrete Industries
Additional to this, for a set of products you may extract compliance data into Excel using several predefined templates for data export.
The Consulting Solution that helps you out of the SCIP trap
Having SAP Product Compliance in place and using the new SAP Consulting Solution (that is currently - end of June 2020 - under development and exists as prototype) you can easily submit your data to ECHA SCIP database with a few clicks.
Mandatory data you need to think about:
- Product data with SVHC and the declared SVHCs: directly out of SAP Product Compliance
- Material classifications: while having full material declaration, the system will calculate the respective classification automatically
- TARIC code: should be already available in your logistic data of the product in SAP
SAP Product Compliance will use this information and push your data to SCIP.
How does the interface work?
Overview on Consulting Solution for SCIP
Having SAP Product Compliance in place and maintained basic material and/or received supplier information, the system calculates the compliance status for your product.
Then with a few clicks - as the figure below shows - you can easily send the affected product data to SCIP database:
Consulting Solution in Action
Conclusion
Time is racing and ECHA does not allow you to be late! Benefit from the advantage of a reliable sustainability product of SAP (SAP Product Compliance for Discrete Industries) and the fast responsive supplement SAP Consulting Solution for interfacing ECHA SCIP database via CDX collaboration platform. Contact the author today to get the latest inside of our service portfolio regarding product and material compliance in conjunction with supplier collaboration platform CDX for e.g. ECHA SCIP.
© SAP Deutschland SE & Co.KG June 2020
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