CDX WEBINAR ON SCIP #1 - SCIP INTRODUCTION - MARCUS SCHNEIDER 2020, FEB 26TH - FEBRUARY 26, 2020
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February 26, 2020 CDX Webinar on SCiP #1 – SCiP Introduction Marcus Schneider 2020, Feb 26th © 2020 DXC Technology Company. All rights reserved.
Disclaimer DXC makes no representations or warranties about the accuracy or suitability of any information in the webinars and related materials; all such content is provided on an “as is” basis. DXC HEREBY DISCLAIMS ALL WARRANTIES REGARDING THE CONTENTS OF THESE MATERIALS, INCLUDING WITHOUT LIMITATION ALL WARRANTIES OF TITLE, NON- INFRINGEMENT, MERCHANTABILITY, AND FITNESS FOR A PARTICULAR PURPOSE. DXC hereby disclaims all liability for any claims, losses, or damages in connection with use or application of these materials. DXC does not guarantee, warrant, or endorse the products or services of any firm, organization, or person, other than its own. The information contained in these webinars and related materials has been prepared, compiled, or provided by DXC as a service to its customers and is not intended to constitute legal advice or the rendering of legal, consulting, or other professional services of any kind. Users of these materials should not in any manner rely upon or construe the information or resource materials in these materials as legal, or other professional advice and should not act or fail to act based upon the information in these materials without seeking the services of a competent legal or other professional. © 2020 DXC Technology Company. All rights reserved. February 26, 2020 2
Who is talking to you Marcus Schneider Senior Consultant DXC.technology • Responsible industries contact aviation, shipbuilding, plastics • 20 years as a consultant with DXC (then EDS, HP(E)) • Focus on compliance & sustainability information management in the supply chain • Background in software development, architecture and B2B integration This webinar will be recorded. © 2020 DXC Technology Company. All rights reserved. February 26, 2020 3
What to Expect for Today‘s Session © 2020 DXC Technology Company. All rights reserved. February 26, 2020 4
About DXC Technology The world’s leading companies rely on With decades of experience driving DXC Technology to run their mission- innovation, our customers trust us to critical systems and operations while deploy our Enterprise Technology modernizing IT, optimizing data Stack to deliver new levels of architectures and ensuring security and performance, competitiveness and scalability across public, private and customer experience. hybrid clouds. © 2020 DXC Technology Company. All rights reserved. February 26, 2020 5
DXC Technology at a glance ~$20B 200+ partner network with ~6,000 global IT services leader best-of-breed partners customers 200+ Fortune 500 companies 60+ years of innovation ~138,000 #122 employees worldwide in the 2019 Fortune 500 delivering mission-critical systems for customers 100 earned top score: 2019 70+ 10,000+ countries Agile/DevOps Disability Equality Index professionals © 2020 DXC Technology Company. All rights reserved. February 26, 2020 6
Creating value across the stack • Organizations want to modernize their IT and analytics capabilities to unlock new insights, create revenue and drive efficiencies. • DXC makes customer information more visible and actionable across functions. • Our Enterprise Technology Stack allows customers to drive business transformation and accelerate growth. • We help customers determine where workloads are best suited — and how to harvest data to generate meaningful insights. © 2020 DXC Technology Company. All rights reserved. February 26, 2020 7
Customers and industries we serve Insurance Healthcare & Travel, Banking & Aerospace & Life Sciences Transportation Capital Markets Defense & Hospitality 6,000+ Consumer & Retail Energy, Utilities, Oil & Gas Manufacturing & Automotive Public Sector Technology, Media & Telecommunications customers around the world across a variety of industries © 2020 DXC Technology Company. All rights reserved. February 26, 2020 8
“ We inspire our people to do fantastic work for customers so they can grow their business. Our intimate knowledge of our customers’ mission-critical systems lays the foundation for deriving insights from those systems that deliver new levels of performance, competitiveness and customer experiences.” Mike Salvino President and Chief Executive Officer DXC Technology © 2020 DXC Technology Company. All rights reserved. February 26, 2020 9
CDX Many regulations exist that require CDX is a swiss army knife: it covers reporting on substances in materials many regulations; imports, exports and/or articles. Also many tools and data and converts data formats; formats exist on the market that focus on aggregates sourced data and does these legal requirements. Only few exist compliance analyses; integrates that focus on multiple requirements. Even data from and to inhouse processes less tools and data formats exist that both cover a wealth of regulations, support And supports the full vertical supply many data standards, integrate into chain communication in a inhouse processes, while covering the full standardized and safe approach supply chain communication. © 2020 DXC Technology Company. All rights reserved. February 26, 2020 10
New Compliance Regulations Per Region / Year Regelwerke in regard to • Chemicals / substances • Packaging • Batteries • Waste • Energy & Security Source: © 2020 DXC Technology Company. All rights reserved. February 26, 2020 11
Compliance and Risk • Material information reduces •Less amendments due to adequate product design Compliance risk and cost in production, helping to avoid material •Amendment risks are more likely to Management is part of shortcomings be identified risk management in all phases of the product life cycle Design Sales Disposal / EOL Compliance data must be kept up-to-date • If materials or Production Maintenance suppliers change • If regulations change • If a product undergoes relevant • Material information •Avoidance of refusals and •Minimization of disposal risk changes within its supports choice of riskless materials and warranty issues by high-value product information through adequate documentation and avoidance of problematic life-cycle thus lowers product •Strengthening of market position substances / materials risks by „certificates“ © 2020 DXC Technology Company. All rights reserved. February 26, 2020 12
What is CDX? One process for the complete value chain! Request Tier 3 Tier 2 Tier 1 OEM Participants provide Supplier safeguarded Supplier Supplier Product information – their product, their Supplier Supplier knowledge, their responsibility! Supplier Supplier Information Aggregation Supplier Supplier Supplier Sourcing at the producer – a Supplier Material question of risk and liability. Composition Supplier Report Tier 3 Tier 2 Tier 1 OEM © 2020 DXC Technology Company. All rights reserved. February 26, 2020 13
WFD & SCiP – Setting Context The WFD (Waste Framework Directive) of SCiP (Substances of Concern in the EU (Directive (EU) 2018/851 articles as such or in complex amending the Waste Framework objects (Products)) serves the Directive) is targeted at creating effective purpose of the WFD to enable policies to regulate usage of substances dissemination of information on SoC in the EEA so as to establish closed loop to the recycling industries as well as economies. As a first step, substances the end consumers in the EU, as regulated under REACH are in focus. entitled by their right to know. Industries shall be enabled to better Reporting duties start 5, Jan, 2021 understand and work on recyclable SCiP is mandated by WFD to ECHA, goods, and design for sustainability… as well as establishing what is “required data” © 2020 DXC Technology Company. All rights reserved. February 26, 2020 14
Important to Know - Policy Context © 2020 DXC Technology Company. All rights reserved. February 26, 2020 15
Important to Know - Legal Context • Various legislations analysed and „interfaced“ – Chemicals – Waste – Products • Ecodesign Directive • Upcoming reviews Packaging and Packaging Waste, ELV, Batteries Directive LED TO • Directive (EU) 2018/851 amending the Waste Framework Directive – Reinforce the waste hierarchy – Facilitate recovery through decontamination – New Article 9 on waste prevention objectives/measures, including a new ECHA database – Extended producer responsibility –modulation of fees © 2020 DXC Technology Company. All rights reserved. February 26, 2020 16
SCiP and ECHA‘s Mission • According to §9(2) of the WFD, its purpose is – „To establish and maintain a database for information down in the supply chain on substances in articles“ – „To provide access to the database to ‚Waste Treatment Operators‘, and to consumers (upon request)“ • This activity has been mandated to ECHA, including the needed definition of „what is required“ to – Enable submission on articles and contained substances – Disseminate information, so that the purpose of the directive can be adhered to (RECYLABILITY) • This leads to a situation, where „what is required“ exceeds requirements from REACH §33 © 2020 DXC Technology Company. All rights reserved. February 26, 2020 17
SCiP in Detail SCiP is about collecting information on Although it is stated that the initial substances of concern in articles scope is REACH §33, this is not an respectively products containing articles. exact reflection on the requirements. While the initial scope is enforcement of Substances from the candidate list, REACH §33 reporting, it is important to the 0.1% threshold, the article understand, that WFD does not talk about definition are all derived from §33, SVCH, but SoC – which will include in but there is data beyond, as future iterations reporting of scarce envisioned by ECHA. materials, plastics in regard to their recyclability quota etc. etc. © 2020 DXC Technology Company. All rights reserved. February 26, 2020 18
SCIP planned timeline IUCLID Format publication • 1st IT User Legal SCIP Initial Q&A and Prototype group WebEx requirements submission public material release • Workshop open into local law version 1.0 to all CDX Planning & preparation Implementation & testing Customer involvement Initial production release © 2020 DXC Technology Company. All rights reserved. February 26, 2020 19
SCiP – Process view Provide their ECHA API key for S2S authentication CDX will support scenario, provide minimum required information. Technical details partly published by ECHA © 2020 DXC Technology Company. All rights reserved. February 26, 2020 20
SCiP – What to Report ECHA requires Material Categories, which are not part of §33 – and ECHA introduces a new categorization scheme that can not be fully mapped to existing schemes No Soc, no report duties. Only those articles within complex products • Every produced must be reported that contain SoC. permutation of a product, There is no need for intermediate no „150%“ declaration, structures. covering variances. • Family reports possible, if The wheel levels are optional, as „the same“ in regard to they not directly contain SoC. Only reportable content the O-rings are mandatory, as they are the article! © 2020 DXC Technology Company. All rights reserved. February 26, 2020 21
SCiP – Dossier IUCLID Dossier Article Safe use + Concern Identifications + instructions element © 2020 DXC Technology Company. All rights reserved. February 26, 2020 22
SCiP – Identifying Articles ▪Article name ▪ Article category: TARIC/CN code + description ▪Other names (TARIC list) ▪Brand* ▪ Model* 73181582 - Base metals and articles of base metal > ▪ Type* Articles of iron or steel > Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel > Threaded articles > Other If an article is a consumer good, the screws and bolts, whether or not with their nuts or additional identifiers might be required for washers > Other > With heads > Hexagonal heads > identification Other, with a tensile strength > Of less than 800 MPa https://ec.europa.eu/taxation_customs/business/calculation-customs-duties/what-is-common-customs-tariff/taric_en This information is required. The nomenclature is an up to 5- Information from level nested picklist of about 16.000 entry codes + exhaustive Oct, 1st 2019 description © 2020 DXC Technology Company. All rights reserved. February 26, 2020 23
Introduced to CDX – Picking Article Categories Soon to be expected in CDX © 2020 DXC Technology Company. All rights reserved. February 26, 2020 24
Identifiers (numeric or alphanumeric) ▪ECHA Article ID ▪GTIN (Global Trade Item Number) ▪EAN (European Article Number)* ▪GPC (Universal Product Code) ▪JAN (Japanese Article Number) ▪UDI (Unique Device Identification) ▪ISBN (Int. Standard Book Number) ▪Catalogue Number ▪Batch Number ▪Part Number One primary identifier is required – for end- Information from consumer products it is the EAN. Other Oct, 1st 2019 identifies might be added as well © 2020 DXC Technology Company. All rights reserved. February 26, 2020 25
Safe use instructions “No need to provide safe use information beyond identification of Information that ensures the article’s safe use, including its proper management at the waste stage Candidate List - Free text field substance” Disassembling instructions - Pdf document Information from Oct, 1st 2019 © 2020 DXC Technology Company. All rights reserved. February 26, 2020 26
Concern Element ▪Candidate list version ▪Candidate list substance ECHA provides picklist of valid ranges, at least 0.1% to ▪Concentration range 100% is required ▪Material category and/or Mixture category The category scheme level 2 from ECHA does not 100% match existing classification schemes used in the industries, i.e. in IMDS or CDX, causing massive effort for repeated reporting, unless the „other“ Information from category might be applicable. Oct, 1st 2019 © 2020 DXC Technology Company. All rights reserved. February 26, 2020 27
Mock Up for Submission The API key is provided by ECHA registration. It is maintained in CDX by the Company Admin, for the root company, optionally per OU, Provide Link to WCM (MDS overriding Explorer). If predecessor possible direct linkt to job © 2020 DXC Technology Company. All rights reserved. February 26, 2020 28
Rules – When Checks Happen • rules CDX can not adapt from IUCLID Contextual rules & • Failure leads to discarded submission IUCLID Checks • Either get failure or submission ID back to CDX • CDX to adapt as possible rules that pertain to IUCLID dossier • Failure leads to discarded dossier submission IUCLID Rules • Rules that pertain to CDX reporting and compliance validation • Only released MDSes may be submittedno direct • No direct submission of received MDSes CDX Validations © 2020 DXC Technology Company. All rights reserved. February 26, 2020 29
Questions? © 2020 DXC Technology Company. All rights reserved. February 26, 2020 30
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