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Industry representatives start talks on cross-sector material declarations

People - Timo Unger

Industry representatives have held an initial discussion on how to develop a solution for collecting and sharing material data for articles – including their chemical composition – across sectors.

The delegates, who met on the sidelines of Chemical Watch’s Global Business Summit in Amsterdam this week, agreed on the benefits of a common way of communicating information. This could facilitate the collection and sharing of material composition information; allow companies to better identify substances of very high concern (SVHCs); and ensure compliance with changes and provisions in chemical regulations around the world.

Some of the sectors represented in the closed meeting – including those from the automotive, electronic, aerospace, apparel, furniture and chemicals industries – have their own material declaration systems. But currently these do not communicate or share information between companies, despite many suppliers selling the same articles and components to multiple sectors.

Speaking at the summit on Tuesday, Mr Timo Unger, on behalf of the European Automotive Industry Association (Acea), said there are four points that need to be considered in developing a cross-industry solution. These are:

  • agreement of a common data structure, whether it’s in xml format or an online tool;
  • a common understanding on the level of detail to be communicated;
  • agreement on data quality; and
  • a common understanding of data security.

"Only if these things are harmonised across industry, can the sectors then share information with other industries' systems," he said.

ECJ ruling

The need for such a solution became particularly important, following the European Court of Justice’s (ECJ) 2015 decision to apply the 0.1% threshold for notifying SVHCs in articles, to "each of the articles incorporated as a component of a complex product" rather than to the entire article.

Some industry groups have consequently expressed concern about how they will be able to comply with REACH Article 33. This requires companies to respond to a request for information if a product contains any SVHCs above a concentration of 0.1%. They must provide this free of charge and within 45 days.

Since the ECJ decision, some industry representatives have called for a review of the provision.

The need for such a common standard has become particularly important, following the ECJ's 2015 decision and the Commission's circular economy package, which will include an amendment to a provision in the waste framework Directive requiring suppliers of articles to provide information pursuant to REACH Article 33," Cefic’s Erwin Annys

Cefic’s REACH director Erwin Annys told Chemical Watch: "The need for such a common standard has become particularly important, following the ECJ's 2015 decision and the Commission's circular economy package, which will include an amendment to a provision in the waste framework Directive requiring suppliers of articles to provide information pursuant to REACH Article 33."

Win win

Upstream industries, including chemicals manufacturers, said Mr Unger, would be the "biggest winners" from such a solution because they currently communicate information to all those downstream. "Upstream companies are not only receiving one request for substance information in one format, but hundreds of requests in hundreds of formats."

Cefic’s Mr Annys agreed: "The European chemical industry has for many years backed the need for one common system to communicate information on chemicals up and down the supply chain."

However, he said it must be a "flexible system that has the ability to work with current industry platforms, such as the automotive industry's International Material Data System (IMDS)."

One representative from a major electronics firm - who did not want to be named - agreed that a common standard for sharing material data and chemical composition, that also allowed the continued use of current sector systems, would help several industries distribute data across the supply chain and reduce overlapping requests for information.

Mr Unger also warned that if industry did not put in place a solution, others would "define the rules".

The Commission recently said it will launch a feasibility study, to be completed by the end of 2019, on the use of different information systems. This would trace technologies and strategies which could enable relevant information to flow along article supply chains and reach recyclers. 

The idea of a cross-sector communication solution was also discussed at last year’s Chemical Watch Global Business Summit.

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