Following the decision to postpone IMDS Release 13.0 from March 10th, 2021 to May 19th, 2021, a special newsletter focused on SCIP reporting was published in IMDS on Feb 26th, 2021. IMDS Steering committee has shared their views, assisting all automotive stakeholders for efficient SCIP (Substances of Concern in Products) reporting - the latest regulatory requirement, which has become a legal mandate for all EU Industries from 5th Jan 2021.

It also throws some insights on the IMDS SCIP functionalities which will go live with IMDS release 13.0.

Meantime considering the SCIP legal mandate, the majority of the duty holders have already started making SCIP submissions with existing IMDS data and faced many roadblocks amid the journey. So, to simplify the process, the IMDS Steering committee is requesting all the relevant parties to follow the below-listed recommendations while creating IMDS data for new parts.

a) Regarding Article Names & Identifiers

Finally, all the data submitted to the SCIP database will be disseminated to the public including Consumers, Government/NGO Authorities & Waste operators. So, to avoid any disclosure of confidential information, proper care has to be taken while entering component/semi-component names. Besides, it should be descriptive enough to identify the function of the article and preferably in English which will facilitate better interpretation.

It is mandatory to enter the part number or other unique identifier for all components since it plays a vital role in SCIP reporting.

b) SCIP reporting for Glass & Ceramics

ECHA is requesting to make SCIP notifications only for articles if SVHCs are present in their final state. In the case of glass or ceramics, Boron (e.g., diboron trioxide, boric acid, and disodium tetraborate) and lead (e.g., lead oxide) substances in the Candidate List which is used in the production process, may not be present as such in the final article. So, in such a scenario, there is no SCIP obligation, nor any communication duties stated under Art. 33 of REACH.

Bearing this in mind, the IMDS committee is suggesting not to report these substances to SCIP based on reported IMDS classifications.

c) Filling of SCIP attributes in IMDS

While comparing IMDS and SCIP information requirements, there are certain missing attributes for which default values will be provided while pushing data to the SCIP database. The default values provided will be generic ones and won’t be suitable for all cases. Thus, it is recommended to perform a prior check and make necessary changes to ensure the data quality and avoid further data resubmissions.

The SCIP settings will be slightly different for New MDS and Legacy/existing MDS as shown in the below table.

d) The discrepancy between IMDS & ECHA SVHC substance list

Automotive Industry organizations like ACEA and CLEPA have raised concerns to ECHA officially regarding denominations of SVHC substances.

The SCIP- SVHC picklist (released by ECHA) contains 370 individual substance names of which 19 have no CAS numbers (9 with EC number), 105 have no EC number (95 with CAS numbers) and 10 have neither CAS nor EC numbers. Besides, the picklist includes 23 so-called group entries which do not describe individual substances at all.

Considering this, ACEA and CLEPA proposed a list of substances (more than 400 substances) with unique identifiers and were approved by ECHA as SVHC substances. However, it has not been reflected in the revised list with Jan’21 updates. And due to this, the Auto Industry is not able to report the SVHC details properly to ECHA, since the relevant entries are missing in the ECHA SCIP candidate list package. Discussions are ongoing and currently, everyone is expecting a fix with the upcoming SVHC list revisions.

Meantime, APA Engineering is successfully reporting these substances accurately using our system-system software solution, Green check. To adopt the best practices for meeting your SCIP requirements and IMDS, please contact us immediately.

   

If this regulation is applicable to you and you are interested in knowing more about this topic and available solutions, then schedule a free consult with our experts.