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Previous articles in Electronic Design have highlighted the need for specific usages of lead in electronic components, options for materials containing halogens and phthalates, and 2015 and 2018 updates on how supply chains can declare environmental data using the IPC-1752A standard. Here we focus on EU REACH (Registration, Evaluation and Authorisation, of Chemicals), a Regulation of the European Commission. It includes requirements for industry to communicate information to customers about the REACH Candidate List of Substances of Very High Concern (SVHC) published by the European Chemicals Agency (ECHA).
Unlike the RoHS Directive (Restriction of Hazardous Substance), which essentially bans shipment of products in the EU if certain substance thresholds are exceeded (except for specific Exemptions), any product containing REACH SVHC may still enter the market—however, new reporting obligations must be met.
The latest implementation of the EU’s Waste Framework Directive (WFD) requires companies to report directly to an ECHA database, called Substances of Concern in Products (SCIP). While you will still need to ask your suppliers and report to your customers the status of REACH—whether the product contains SVHC or not—only those items containing SVHC in concentrations greater than 0.1% must be reported to the SCIP database. In this article, we discuss the database’s background and driving force for SCIP reporting, and we show how it can be accomplished.
EU Waste Framework Directive and Circular Economy
The goals of the WFD are noble and broad: to lead to a more circular economy where resources are recycled and recovered rather than discarded, hazardous substances are minimized, and more transparency is provided to end customers and waste operators fulfilling recovery roles. These are the main objectives of SCIP reporting:
“1. Decrease the generation of waste containing hazardous substances by supporting the substitution of substances of concern in articles placed on the EU market.
2. Make information available to further improve waste treatment operations.
3. Allow authorities to monitor the use of substances of concern in articles and initiate appropriate actions over the whole lifecycle of articles, including at their waste stage.”
More generally, the EU is also moving forward with prioritizing and implementing its Green Deal to fight climate change and develop a sustainable economy. These efforts stand in sharp contrast to other regions like the U.S., where green new deal legislation has stalled, and the topic of climate change remains divisive. Meanwhile, if you want to do business in the EU, read on.
Currently the SCIP database is operating in test mode through October 2020. Thereafter, manufacturers may start to report to the production database, and in fact must, do so by Jan. 5, 2021. Next we explain what new information is required for SCIP, followed by options you have for doing the reporting itself, as well as getting the new information you will soon need.
SCIP Reporting Requirements
If your company does business in the EU, most likely you already have been collecting data on which items contain REACH SVHC. Actually the regulation applies to Articles, defined as “an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition.”
In other words, unshaped raw materials, liquids, etc. aren’t themselves Articles. However, in most cases, electronics products are either simple articles, or assemblies of articles called Complex Objects. And if the Article is made with a mixture or solution, for example, an adhesive, that itself contains the SVHC, then the resulting Article contains the SVHC, too.
For companies already meeting the existing REACH obligation, the basic information you’re already tracking includes:
- The article: the number, SKU, etc.
- The SHVC substance itself: description, CAS or EC number, and possibly the % concentration
- Safe use information that must be shared with the public
SCIP introduces several new reporting requirements. These are mandatory:
Primary Article Identifier Type: While it’s mandatory that you choose a specific identifier for each article, your company likely already has this information. Choices include global trade item number, universal product code, catalog number, item number, and part number, as well as Other.
Production in European Union: While an answer is mandatory, Unwilling to Disclose is a valid choice.
Article Category: This is defined under a system of Combined Nomenclature (CN code), as found in the trade Taric Helpdesk. This new attribute may come as a surprise unless you’re already assigning harmonized tariff codes. While there are some 20,000 valid codes, those for commodities like live animals and works of art will not be applicable for electrical goods.
Material Category: This is a new, unique, and very specific list of material types where the SVHC is located. Because your products may likely contain substances with RoHS exemptions, for example, lead or cadmium, here we list some of the material categories you will likely encounter and need to report. Of course there may be others not listed here, as the latest January 2020 SVHC list includes 205 substances in all. There’s a general category called Other that we understand may be reported initially, until this new kind of data becomes available.
- glass > borosilicate glass (common example, lead borosilicate)
- metal > brass (machinable brass containing lead)
- metal > cadmium and alloys (silver cadmium oxide contacts)
- metal > lead > lead alloy (high temperature solder)
- ceramic > oxide ceramic > lead zirconium titanate (PZT) ceramic
- metal > aluminum alloys (machinable aluminum containing lead)
- metal > steel > alloy steel except stainless steel (machinable steel)
- plastic and polymers > polyvinylchloride (PVC), soft, (with phthalate plasticizers, no RoHS Exemptions apply)
- Various materials requiring flame retardants that are SVHC (no RoHS exemptions apply)
Mixture Category: This category can be used to report the mixture that contains the SVHC, which as a result means the article so assembled contains that SVHC. There are some 200 available mixture categories, most of which don’t apply to electronics, while those you may need to be aware of and report include adhesives, coatings, lubricants, and colorants.
Linked Article: A higher-level assembly containing one or more articles as such will need to report this hierarchy as well.
Safe Use Information: This should already be available according to the original REACH requirements, but along with the other items in this section is newly added to the IPC-1751B material declaration standard as discussed below.
At this time, it’s optional to report or not report any of the following data: dimensions, volume, weight, density, and color. One observation is that unless the article weight is known, the SCIP database will be incapable of determining how much SVHC is being reported on a mass basis. Again, with regard to electronics using small amounts of SVHC in the examples listed in the Material Category discussion above.
However, at the same time, the goal of further reducing SVHC isn’t an easy one, since in most cases there aren’t technically viable, much less commercially available, substitutes for many of the SVHC in electronic components. The few exceptions might include PVC, for which some alternate materials are available to avoid additives that are SVHC, and alternatives to halogenated flame retardants used in plastics that aren’t SVHC. Besides the potential for RoHS exemptions not being renewed, no longer having to report to SCIP is clearly another incentive to design SVHC out wherever possible.
A count of the REACH January 2020 SVHC list (see table) shows the following (counting just the entries for SVHC) containing halogens (fluorine, chlorine, or bromine) and those based on phthalic acid including the phthalate esters (phthalates).
The count is based on the full listing containing multiple rows for related substances. The list is commonly known as the “205” list, but in the expanded listing note that the total SVHC count is 295. The takeaway here is that these two categories alone account for nearly one quarter of the reportable SVHC and replacements would be more than welcome.
One Format, Three Ways to Report
The mandated format for SCIP reporting is a dossier, which must be in IUCLID format. This format, designated the International Uniform Chemical Information Database, is already in use and maintained by ECHA. The data is in XML (extensible markup language), which is a format used for data sharing. It consists of data elements (tags) and the data itself. While the IPC-1752 series of declaration standards also are XML-based, the specific schemas are different from IUCLID.
A client application for IUCLID is available. A user may enter the required SCIP information in a dataset, validate that it meets the criteria for reporting, and create a special zip file called i6z that’s suitable to transmit to ECHA.
Rather than perform manual entry, larger companies with many products may decide to collect the information electronically from existing databases, compile it into the specified format, and create the i6z dossier files that way. The final step, which can also be automated, uses the ECHA System to System portal. It transmits the dossier across a webservice to the SCIP database itself.
A third option is to use a service provider to collect the supplier data, filter for items with SVHC, and report directly to SCIP. The choice depends on your company’s current environmental data-collection method and business model.
Either way, each dossier will need to be validated to ensure it meets the format and content requirements, and when accepted into SCIP will create a unique submission number. The IUCLID client itself contains pull-down menus for Article, Material, and Mixture categories. For automated collection and reporting, the same menus are available as pick lists of valid values. Each has its own numeric identifier code and text, which become part of the XML statements within the dossier.
Getting All the Data: A New IPC Standard
As referenced in the introduction, the IPC-1752A Material Declaration Standard has been in use across the industry for years. A revised standard, IPC-1752B, is scheduled for release in July 2020. This new release supports collection and reporting of all the new elements required for SCIP in the supply chain. So looking ahead, this is one good way to fully enable your own SCIP reporting.
Of course, as with any major revision, 1752B implementation and adoption will take some time. Service providers will need to enable the new attributes in IT systems, both for receiving the new files and reporting the new attributes. Most importantly, suppliers will need some time and training to get up to speed on reporting the new data and using the new standard.
As with IPC-1752A, the revised IPC-1752B standard defines the XML machine readable schema for reporting. Significant efforts were put into its initial drafting, revision, and final ballot approval by the Material Declaration Task Force E-31B and its stakeholders to make this a reality. Efforts also continue to harmonize as much as possible with related IPC standards, including IPC-1754 for Aerospace and Defense and Other Industries, and with the IEC62474 declaration standard.
While a full material declaration will continue to be very useful as Class D declaration, the use of the other classes of reporting may also experience an increase in utility, often in combination with Class D homogenous material declaration. For example, a Class A declaration could directly state whether the item has REACH SVHC or not, while the Class C declaration would offer improved ability to report SVHC at the product level.
Conclusions
The new WFD and SCIP reporting requirements will have an impact on electronics manufacturers who already need to manage multiple substance lists (EU RoHS, China RoHS, etc., REACH, California Proposition 65, and so on.) New data will be required to be collected and reported, and for the first time for many companies, reported directly into a regulatory database. Some options do exist for how the data and final dossiers are reported, although the reporting format itself is fixed as IUCLID.
The revised IPC-1752B standard should be very helpful for industry-wide efforts to comply with SCIP as support for it is rolled out to IT systems and across the supply chain. Always keep in mind that the goal of this additional work is for a good reason—to lead to better management of resources and material selection for a healthier environment and a more sustainable world, at least in the EU.
In a subsequent article, we plan to show real examples of products reported with SVHC and how they can be searched by concerned stakeholders. Case studies of what was learned from SCIP reporting, hopefully with success stories about achieving some of the goals of the WFD and a circular economy, will be found and presented. Electronic components and materials without SVHC are invited to help us all out.
Acknowledgement
Thanks to Dr. Aidan Turnbull, Director, BOMcheck, and co-chair of the IPC E31-b Material Declaration Task Group.
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