Toxic heavy metals and other hazardous substances, won as a raw material from natural deposits, come on combustion processes, effluent and waste in the environment and therefore into the human food chain. To protect the environment, as well as the health of people, the use of these substances now requires reporting obligations with severe limitations, and sometimes a complete ban in many industries.
REACH, RoHS, WEEE, ELV, RRR, or the Hong Kong Convention (HKC) are the most well-known material legislations. However, a vast quantity of national legislation exists worldwide, and continues to increase. To comply with all this legislation, clear identification and reporting of materials used in the supply chain is needed. Without standardized processes and tools it is extremely difficult, if not impossible, to exchange defined data throughout a global supply chain.
CDX is the answer. CDX enables a company to create, receive and evaluate the information required for the maintenance and reporting of material compliance data within or cross industry while protecting intellectual property.
CDX Extends Support for Waste Framework Directive
"Substances of Concern in Products (SCiP)" Database Reporting
DXC Technology is an active participant in the technical reviews and validation as the SCiP database is implemented. The SCiP database reporting requirements foundation is REACH Article 33 reporting, and leverages the existing ECHA IUCLID REACH Chemical database architecture, with further refinement in progress. The DXC CDX team is currently reviewing the IUCLID interface specifications and preliminary SCiP requirements, and is preparing capabilities to support our clients with SCiP reporting obligations. Once the SCiP interface specification is available, DXC plans to provide an interface for client-authorized semi-automated upload from CDX into the SCiP database. Further requirements for SCiP reporting will be implemented in CDX as necessary, reasonable, and technically feasible, and as required for client REACH compliance.
Companies actively using CDX today to collect and maintain supply chain full material and REACH SVHC product substance declarations will be well prepared to comply with the requirements of SCiP database registration reporting, and other relevant aspects of the REACH regulation. CDX offers comprehensive functionality and a systematic approach to collect and analyze substances relevant under the REACH Regulation. CDX also addresses many other product content concerns, with managed regulatory thresholds and exemptions, sunset dates, and exceptions. CDX is the leader in multi-industry product sustainability, regulatory substance & corporate responsibility data collection, reporting and analysis since 2011.
European Commission (EC) Directive (EU) 2018/851 amends Directive 2008/98/EC on waste (The Waste Framework Directive) to require all EU product producers and importers to enter product registration information into a centralized substance database for all articles and complex products that contain REACH Candidate List substances above 0.1% w/w. The amendments also instruct the European Chemical Agency (ECHA) to create the repository into which these product registrations will occur. ECHA has completed the initial development of the database for these "Substances of Concern in Products" (SCiP). The SCiP database will collect and maintain this Product and Substance of Concern information and provide waste treatment operators and consumers access to the information upon request. This information is intended to reduce further hazardous chemical contamination and to promote the circular economy.
Each member nation of the EU will implement and define individual regulations to enforce the SCiP reporting requirements through 2020. EU product producers & importers begin SCiP database submissions on 5 January 2021. Registration is an extension of the June 2011 REACH obligation to notify downstream product recipients of the presence of Substances of Very High Concern (SVHCs), and so impacted EU product producers and importers are legally obliged and expected to know which products are impacted and have the required information for entry at implementation. As currently written, the Directives require every company producing a relevant product (article or complex object) in the EU, or which is imported into the EU, to report (known as the "Once An Article, Always An Article" or O5A Decision). Suppliers thus share the reporting obligation, even if the finished good producer is the only importer into the EU.
Regulation 1272/2008/EC on
Classification, Labelling and Packaging of substances and mixtures
End of Life Vehicles
Ship Recycling Regulation
Hong Kong Convention for the
Safe and Environmentally Sound Recycling of Ships
Registration, Evaluation and Authorization of Chemicals
Restriction of the Use of
Certain Hazardous Substances
Type-approval of motor vehicles
with regard to their Reusability, Recyclability and Recoverability
Waste Electrical and Electronic Equipment
Directive (EU) 2018/851 amending Directive 2008/98/EC on waste:
Waste Framework Directive