SAP Product and REACH Compliance. REACH Compliance

Transcription

1 SAP Product and REACH Compliance REACH Compliance

2 TABLE OF CONTENT REACH COMPLIANCE CHECKS... 3 General Considerations... 3 Use Determination Check... 3 Use Coverage Check... 3 REACH SVHC Check... 4 MANAGING REACH COMPLIANCE FOR PRODUCTS... 5 Process... 5 Result... 5 COLLECTING AND ASSESSING PRODUCT USES... 6 Prerequisites... 6 Procedure... 6 Result... 7 CHECKING CUSTOMER USES AND COPYING TO PRODUCTS... 8 Prerequisites... 8 Procedure... 8 Result... 8 Example... 8 More Information... 8 SUPPLIER COLLABORATION... 9 Recommendation... 9 Procedure... 9 Result... 9 CHECKING PRELIMINARY REGISTRATION STATUS AND COPYING TO PRODUCTS Prerequisites Procedure Result

3 REACH COMPLIANCE CHECKS General Considerations You can perform the REACH checks for all specifications that have a material assigned to them. You can also perform the checks for multiple materials assigned to a specification. The check is executed when at least one material fulfils the requirements for the check. The status of the check is displayed using an icon. Check results are aggregated on the higher product structure levels using the worst case scenario. For example, the least successful registration status is rolled up to the product. You can substitute a customer-specific property such as Use and Exposure Scenario for the Use Collection property. Use Determination Check This check is used to check the uses that you collected from your customers and to copy these uses to the product. You can also use this check to create tasks and s to communicate with your customers. The system copies the customer-specific uses in the Customer Use Collection property to the Use Collection property on the product level. We recommend that you schedule this check to run automatically to copy the uses to the finished product at regular intervals. For more information, see Worklist Management. The system checks the following material types: substances, preparations, and products with the REACH material nature Article with Intended Release and Container. The check reads all customers assigned to the product and in the REACH area. If the substance is marked as used as intermediate, also customers assigned to the product and outside REACH area. Use Coverage Check You use the use coverage checks at several stages of the REACH registration process. It has two functions: 1. Part 1: Check and transfer uses within the product structure Check and transfer uses within the product structure. Rolls uses down the product structure to the real and pure substances that are assigned to the use and exposure composition and creates tasks/ s to request missing data from suppliers. This part of the check uses the Use Collection property. 3

4 2. Part 2: Roll Up Preliminary Registration Status to Product Rolls up the preliminary registration status of uses at the real substance level to the product and aggregates the check status/result. Note The use coverage check does not roll up the registration status of uses with the evaluation status Not relevant or Assessment required or Must be notified. If you want to register a use yourself, set the evaluation status Must Be Notified for the purchased substance. The system then ignores the registration statuses for uses in the supplier specification and only considers the pure substances in the use and exposure composition. The use coverage check uses the use and exposure composition, the supplier listing, and the monomer composition. The monomer composition is only shown if a polymer pure substance is part of the product structure and has a monomer composition maintained. If a polymer is purchased from a supplier in the REACH area, no communication is necessary since polymers do not need to be registered. If a polymer is purchased from non EU supplier, you request an only representative exists or a monomer composition. If an only representative exists, you do not need to maintain uses. If you receive a monomer composition, you are responsible for registering the substances so you maintain uses on the pure substance level. For more information about using the use coverage check for customer and supplier communication, see Collecting and Assessing Product Uses. REACH SVHC Check This check helps to ensure the REACH compliance of articles according to the SVHC candidate substances. These substances may not be present in articles above a concentration of 0.1% weight by weight. For more information, see Product Compliance Checks. 4

5 MANAGING REACH COMPLIANCE FOR PRODUCTS You use this process to ensure that your products are compliant with the European REACH regulations. Process 1. You assess your products to see which products are relevant for the REACH compliance process. 2. You collect and assess uses of products and components. 3. You collect the preliminary registration status for these uses from your suppliers. 4. You inform your customers about uses and preliminary registration statuses, report compliance, and assess registrations for product uses. You can use a campaign to send information about all standard uses that are registered or will be registered and uses that will not be registered or are advised against. If a customer use is not supported, the customer can register their own use. Note Feedback from suppliers is preliminary and the customer cannot use the collected information to create their own esds until you send an esds. You can repeat the whole process or parts of the process. You can display an initial overview of the status before you receive all replies from your business partners, and you can enter or remove new business partners and then restart the communication or status determination. We recommend that you maintain your standard uses before you perform the use determination check to reduce the number of data records during the import of customer confirmations. We recommend performing the use determination check before running the use coverage check. This ensures that you ask suppliers about the registration status for all standard uses, own uses, and the customer uses that you support. If you already have maintained registration statuses from suppliers in your system before you perform the use determination check, this information is included in the customer request form. Result You have collected your own uses and your customers' uses. You have informed your supplier which uses you require and collected their registration status You have informed your customers about the preliminary registration status for their uses. You can now use this information to register your substances. For more information, see Managing REACH Registration for Pure Substances. 5

6 COLLECTING AND ASSESSING PRODUCT USES You use this procedure to maintain your own uses, standard uses, and customer uses for REACH-relevant products. Products are stored in the system as SAP materials. There are two ways to collect customer uses: a customer-oriented approach using a campaign, or a product structure-oriented approach using the use determination check We recommend that you collect as many uses as possible before you contact your suppliers. Prerequisites You have made the settings in Customizing for Product and REACH Compliance under Checks. Customer material information records are available for sold products. You have run the material assessment check and it was successful. Procedure 1. Maintain your own uses for hazardous materials on the Use Determination tab in the compliance workbench. Define standard uses that you want to provide to your customers to facilitate communication. 2. Collect uses from customers using one of the following approaches: o Customer-oriented approach We recommend that you use a campaign to collect information from your most important customers. For more information see Campaign. o Product-oriented approach Perform the use determination check to check that the use information is complete for a product. You can create tasks and send request s to your customers as part of this check. In both cases, the system proposes standard uses to your customers and asks them if these uses match the uses that they require. If a customer does not require any further uses, they confirm the uses and return the form. If the customer wants further uses to be registered, the customer can enter these uses and optionally attach further data relevant for the exposure scenarios. If the requested material is an intermediate, the customer can enter the responsible person. 3. Import customer responses 6

7 Use the evaluation status to assess customer uses at the product or purchased substance level. You can indicate that the use is relevant for your company, that you need to assess whether you will support the use, or that the use is not relevant for subsequent process steps, for example a customer defines a use that is only slightly different from the proposed use instead of confirming the proposed use. At the purchased substance level, you can indicate that your supplier will not support the use but you will register the use yourself. Note Only uses with an empty evaluation status or the evaluation status Relevant are later communicated to your supplier as required uses. 4. When you have processed all customer responses, perform the use determination check again to make sure that no information is missing. If information is still missing, you can check that the customer use information is complete and create tasks to request missing information from customers as part of this check. 5. Perform the use coverage check on the Use Coverage tab in the compliance workbench to roll down the uses to the real and pure substances in the use and exposure composition for the product. Note If you do not select any suppliers during this check, then the uses are only rolled down and supplier communication is not started. This check is performed automatically after the campaign but you must execute it manually after using the product structure approach. Result You have collected your own uses, standard uses and customer uses and copied these to the substances contained in the product. You can now use this information to register your substances or to collaborate with your suppliers. For more information, see Managing REACH Registration for Pure Substances and Collaborating with Suppliers. 7

8 CHECKING CUSTOMER USES AND COPYING TO PRODUCTS You use this procedure to check that you have collected uses from all your customers for a product and to subsequently copy these uses to your product. Prerequisites You have made the settings in Customizing for Product and REACH Compliance under Checks. The products are sold products and customer material information records are available. You have run the material assessment check and it was successful. You have maintained standard uses or requested use information from customers. Procedure 1. Select a product and perform the use determination check in the compliance workbench. 2. If the check shows that customers have not reported their uses or have not yet confirmed standard uses, the system suggests that you create corresponding tasks and send s to the relevant customers. If necessary, change the selection of customers, and whether you want to only create tasks for the selected customer or if you also want to send s. 3. Check any error messages and correct your entries, as necessary. Result The system has checked that uses are maintained for all relevant customers. The customer uses that you accepted are copied to the product. When copying use information to the product, the check considers two use entries to be identical when both uses have the same combination of main user group, sector use, end use, product category, article category, and environmental release category. The system copies only the descriptor attributes from the customer to the product; no other attributes are copied or overwritten. Example Customer A reports uses 1 and 2 for product Z Customer B reports uses 1 and 3 for product Z Uses 1 and 4 are maintained for product Z in your system After the use determination check, uses 1, 2, 3, and 4 are maintained for product Z. More Information For more information about the use determination check, see REACH Compliance Checks. 8

9 SUPPLIER COLLABORATION You can use this process to check whether your suppliers support your uses and your customers' uses. For suppliers who are not in the REACH area, you clarify whether they have appointed an only representative, and if not, you ask for the composition data of the purchased material. Communication takes place at the product level. At the end of the process, the registration statuses are rolled up to the product level. Recommendation You can start communication with customers and suppliers at the same time but we recommend that you collect your own uses and customer uses before you collaborate with your suppliers. This ensures that you ask your suppliers about the registration status for all standard uses, own uses, and the customer uses that you support and means that you do not need to contact your suppliers twice. If you perform the supplier communication first and maintain the registration status, this information is included in the customer request forms. You can use campaigns to perform a mass communication process for a large number of materials and customers or suppliers. For more information, see Campaign. Procedure 1. You ask suppliers outside of the REACH area for their only representative or for the product composition. If the supplier does not have an only representative, they must provide composition information that you can use to register the substance yourself. 2. You process replies from suppliers outside of the REACH area. 3. You perform the use coverage check for substances without an only representative that you must register yourself. This rolls the uses down to the pure substances that need to be registered. 4. You communicate the uses of purchased products to your suppliers and only representatives to find out whether they support your required uses and request their preliminary registration status. You can use a campaign or you can use the use coverage check. The supplier enters the preliminary registration status of the uses for the real substance that you provided. They can also enter additional uses and their registration status, declare the product as an intermediate, and modify contact data. 5. You process incoming s from your suppliers to extract relevant data that relates to uses and their preliminary registration status. These s can either be an answer to an inquiry that you initiated or can be triggered by the supplier. The supplier reply is loaded into the external supplier specification. If the supplier specification does not yet exist, it is created. 6. The use coverage check to copy uses and the preliminary registration statuses from the supplier to the product level and to evaluate if the determined uses are covered and a positive registration status is set. This check may be scheduled to take place automatically. 7. After the registration deadline, assess the uses in the supplier esdss and use this information to send esdss to your customers or to register the substances yourself. Result You have collected the registration status of your own uses, standard uses and customer uses from your supplier and copied these to the substances contained in the product. You can now use this information to register your substances or to collaborate with your customers. For more information, see Managing REACH Registration for Pure Substances. 9

10 CHECKING PRELIMINARY REGISTRATION STATUS AND COPYING TO PRODUCTS You use this procedure to perform the use coverage check to make sure that the information from your suppliers about the registration status is complete. You can subsequently roll the registration status up to the product level. Prerequisites You have run the material assessment check and use determination check and they were successful. The substance that you want to check has at least one material assigned to it. The substance is purchased and you have made the settings in Customizing for Product and REACH Compliance under Checks and Material Categories. Procedure 1. Select a real substance in the compliance workbench and perform the use coverage check. 2. If the registration status of the use for a substance or a supplier specification is not maintained, the system suggests that you create tasks and send s to your suppliers to find out the registration status. If required, change the supplier selection and choose whether you want to only create tasks for the selected suppliers or if you also want to send s. 3. Check any error messages and correct your entries, as necessary. Result The system has checked that the registration status is maintained for all relevant suppliers. The preliminary registration statuses are rolled up to the product level. 10

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