Customer

Product compliance – Enhancements for the

new ruling of the ECJ for EU REACH SVHC
Kristian Mitic, SAP
January, 2017
Disclaimer

The information in this document is confidential and proprietary to SAP and may not be disclosed without
the permission of SAP. This document is not subject to your license agreement or any other service or
subscription agreement with SAP. SAP has no obligation to pursue any course of business outlined in this
document or any related presentation, or to develop or release any functionality mentioned therein. This
document, or any related presentation and SAP's strategy and possible future developments, products and
or platforms directions and functionality are all subject to change and may be changed by SAP at any time
for any reason without notice. The information on this document is not a commitment, promise or legal
obligation to deliver any material, code or functionality. This document is provided without a warranty of any
kind, either express or implied, including but not limited to, the implied warranties of merchantability, fitness
for a particular purpose, or non-infringement. This document is for informational purposes and may not be
incorporated into a contract. SAP assumes no responsibility for errors or omissions in this document, except
if such damages were caused by SAP intentionally or grossly negligent.
All forward-looking statements are subject to various risks and uncertainties that could cause actual results
to differ materially from expectations. Readers are cautioned not to place undue reliance on these forward-
looking statements, which speak only as of their dates, and they should not be relied upon in making
purchasing decisions.

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Agenda

Motivation

Article Definition and SVHC Calculation

Configuration Changes

Data Migration / How to enact?

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Motivation O5A
Definition of an article – O5A
What has changed?

• Significant impact on large and complex products

• New ruling of the European
Court of Justice regarding
• Assessing a product gets more time and cost intensive
the definition of an Article • Number of articles has exploded
for REACH-SVHC • Grind testing does not work any more for the product
• Risk Assessment gets more important
• Effective since SEP-10-
2015 • Existing product and Supplier Declarations are
outdated and we have to start again at zero

• Each of the articles • Collaboration Patterns

incorporated as a article • The parts most likely to have candidate substances will not
into a complex product have the necessary data
triggers obligations • Class C Substance Declarations are invalid and have to be
recollected. The accuracy of responses will also be in
according to the REACH- serious doubt
framework, if they contain • Collection of normalized flat BOM has to be redefined
an SVHC-CL substance
above 0.1% by weight • More and more SHVC substance will be reported across
the supply chain

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Definition of an article – O5A
Unchanged - Obligations according to the EU REACH Framework

Duty to Article 33(1) – Any supplier of an article containing a substance meeting the criteria in Article
57 and identified in accordance with Article 59(1) in a concentration above 0.1%

communicate Business to weight by weight (w/w) shall provide the recipient of the article with sufficient
Obligations according to

information, available to the supplier, to allow safe use of the article including,
information Business B2B as a minimum, the name of that substance.

on Article 33(2) –
On request by a consumer any supplier of an article containing a substance
meeting the criteria in Article 57 and identified in accordance with Article 59(1)
substances Business to
in a concentration above 0.1% weight by weight (w/w) shall provide the
consumer with sufficient information, available to the supplier, to allow safe use
in articles Consumer B2C of the article including, as a minimum, the name of that substance. The relevant
information shall be provided, free of charge, within 45 days of receipt of the
request.’
Any producer or importer of articles shall submit a registration to the Agency
Registration Article 7(1) – for any substance contained in those articles, if both the following conditions
EU REACH

are met: (a) the substance is present in those articles in quantities totaling over
and Substance one tone per producer or importer per year; (b) the substance is intended to be

notification of Registration released under normal or reasonably foreseeable conditions of use.

substances Article 7(2) –

Any producer or importer of articles shall notify the Agency, in accordance with

in articles’ Substance
paragraph 4 of this Article, if a substance meets the criteria in Article 57 and is
identified in accordance with Article 59(1), if both the following conditions are
met: (a) the substance is present in those articles in quantities totaling over one
Notification tone per producer or importer per year; (b) the substance is present in those
articles above a concentration of 0.1% weight by weight (w/w).

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Summary – O5A

• Change: The concentration and threshold RoHS like but level of

of a SVHC candidate substance must be the homogenous
calculated against the lowest level of an
Article as defined by the EU REACH
material is the lowest
framework article
• Impact:
• More and more SHVC substances will be
reported across the supply chain, as
• Complex articles consists of thousands of
articles and each of them has to be verified
separately
• No Change: All SVHC candidate
substances with more than 0.1% must be
declared

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Article Definition
Article Definition

• What can a combination of two articles be based on the guidance from ECHA?

• How to classify an article in SAP EHS Management?

• SVHC Calculation in SAP EHS Management

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What can a combination of two articles be?

Examples have been taken from ECHA’s document “Guidance on requirements for substances in articles”. this guidance is currently being updated. For the
latest draft, please see: Consultation procedure or draft to PEG

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What can a combination of two articles be?

Very Complex Objects and special Industry

Use Cases
Examples have been taken from ECHA’s document “Guidance on requirements for substances in articles”. this guidance is currently being updated. For the
latest draft, please see: Consultation procedure or draft to PEG

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How to classify an article in SAP EHS management?

• Worst Case Approach

• REACH Article Classification is preset by the

system
• Basic Materials, Surfaces  Not An Article
• Bulks, Packaging, Part  Article
• Data Migration Report to initialize the
Classification for In Process and Not Relevant Note: If you have already the information
Revisions available that a material is rather a chemical than
an article (e.g. “Environmentally Relevant”
• Article Classification can be manually
changed during Compliance Assessment Indicator in table MARA Field KZUMW or a
corresponding material classification) the BOM
• An Object that contains an Article cannot be transfer can be enhanced to preset this
classified as “Not An Article” classification code in EHS accordingly.

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How to classify an article in SAP EHS management?

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REACH-SVHC Classification code
Data migration and daily work
Code Value Description

_ Initial Undefined Data Migration Report

1 Article Worst Case Approach: System Default is an Article. As long as • Fills the classification default code for all existing
not otherwise stated each Part, Bulk and Packaging is InProcess and NotRelevant Revisions (like the
considered to be an article determination logic)
2 Not an Used for Mixtures, Substances and Preparations
Article Daily Work after O5A shipment:

• New Determination to preset classification code if

code is empty/initial

Determination logic • If Code <> „“ then it has been classified already by the
user or by a user exit in BOMBOS. Value is not
changed
_
CDO Category = Product, Bulk, Packaging
1 • System and/or User assigns the REACH-SVHC
Compliance Requirement Revision the very first time
2
CDO Category = BasicMaterial • The user creates manually a new REACH-SVHC
revision

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SVHC Calculation in SAP EHS Management
Mechanically assembled Object w/o packaging
Total Weight Total Weight
Name Typ Substance CAS Prop. [%] In Name Typ Substance CAS Prop. [%] In
Weight [g] Weight [g]
Product - mech. Packaged Product -
P1 100 P2 105
assembled mech. assembled
chromium (VI) trioxide 1333-82-0 5 0,9 A1 chromium (VI) trioxide 1333-82-0 5 0,9 A1
chromium (VI) trioxide 1333-82-0 10 8 A2 chromium (VI) trioxide 1333-82-0 10 8 A2
dibutyl phthalate 84-74-2 5 0,25 V1
A1 Article 18 chromium (VI) trioxide 1333-82-0 5 0,9 A1 A1 Article 18 chromium (VI) trioxide 1333-82-0 5 0,9 A1
A2 Article 80 chromium (VI) trioxide 1333-82-0 10 8 A2 A2 Article 80 chromium (VI) trioxide 1333-82-0 10 8 A2
A3 Article 2 A3 Article 2
V1 Packaging 5 dibutyl phthalate 84-74-2 5 0,25 V1

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SVHC Calculation in SAP EHS Management
Chemically bound Object w/o Packaging
Total Weight Total Weight
Name Typ Substance CAS Prop. [%] In Name Typ Substance CAS Prop. [%] In
Weight [g] Weight [g]
Product - chemically Packaged Product -
P4 100 P5 105
bound chemically bound
chromium (VI) trioxide 1333-82-0 5 0,9 A1 chromium (VI) trioxide 1333-82-0 5 0,9 A1
chromium (VI) trioxide 1333-82-0 10 8 A2 chromium (VI) trioxide 1333-82-0 10 8 A2

N-methyl-2-pyrrolidone 872-50-4 0,4 0,4 P4 N-methyl-2-pyrrolidone 872-50-4 0,4 0,4 P4

dibutyl phthalate 84-74-2 5 0,25 V1
A1 Article 18 chromium (VI) trioxide 1333-82-0 5 0,9 A1 A1 Article 18 chromium (VI) trioxide 1333-82-0 5 0,9 A1
A2 Article 80 chromium (VI) trioxide 1333-82-0 10 8 A2 A2 Article 80 chromium (VI) trioxide 1333-82-0 10 8 A2
M1 Mixture 2 N-methyl-2-pyrrolidone 872-50-4 20 0,4 M1 M1 Mixture 2 N-methyl-2-pyrrolidone 872-50-4 20 0,4 M1
V1 Packaging 5 dibutyl phthalate 84-74-2 5 0,25 V1

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SVHC Calculation in SAP EHS Management
Chemically bound and coated Object w/o Packaging
Total Weight Total Weight
Name Typ Substance CAS Prop. [%] In Name Typ Substance CAS Prop. [%] In
Weight [g] Weight [g]
Packaged Product -
Product - chemically
P7 102 P8 chemically bound and 107
bound and coated
coated
chromium (VI) trioxide 1333-82-0 5 0,9 A1 chromium (VI) trioxide 1333-82-0 5 0,9 A1
chromium (VI) trioxide 1333-82-0 10 8 A2 chromium (VI) trioxide 1333-82-0 10 8 A2
N-methyl-2-pyrrolidone 872-50-4 0,392156863 0,4 P7 N-methyl-2-pyrrolidone 872-50-4 0,392156863 0,4 P7

dibutyltin dichloride 683-18-1 0,588235294 0,6 P7 dibutyltin dichloride 683-18-1 0,588235294 0,6 P7
dibutyl phthalate 84-74-2 5 0,25 V1
A1 Article 18 chromium (VI) trioxide 1333-82-0 5 0,9 A1 A1 Article 18 chromium (VI) trioxide 1333-82-0 5 0,9 A1

A2 Article 80 chromium (VI) trioxide 1333-82-0 10 8 A2 A2 Article 80 chromium (VI) trioxide 1333-82-0 10 8 A2
M1 Mixture 2 N-methyl-2-pyrrolidone 872-50-4 20 0,4 M1 M1 Mixture 2 N-methyl-2-pyrrolidone 872-50-4 20 0,4 M1
C1 Coating 2 dibutyltin dichloride 683-18-1 30 0,6 C1 C1 Coating 2 dibutyltin dichloride 683-18-1 30 0,6 C1
V1 Packaging 5 dibutyl phthalate 84-74-2 5 0,25 V1

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Configuration Changes
Configuration Changes at a glance
1

• The existing standard Check User Exit

CP_SVHC (1) has been changed to invoke
the new Class
cl_ehprc_check_reach_svhc_o5a (2) 2

• The new check implementation according

to the O5A paradigm considers the new
check criteria (3)

• The User Exit CP_SVHC controls whether

the classification code drop down is
3
displayed in a compliance requirement or
not

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Verify Configuration Changes (1/3)
Standard EU REACH-SVHC Check

• For the standard Check REACH-SVHC that is being used to assess a product regarding the
presence of substance of very high concern (EU REACH SVHC Candidate List):
• Make sure that the user exit configuration of the check REACH SVHC check points to the new
check implementation class or userexit function module
• If you are using a customer specific check implementation based on class
cl_ehprc_check_reach_svhc you have to do the same enhancements for the new check class
cl_ehprc_check_reach_svhc_o5a.

E.g. by replacing the base class of your Z-Class to point to the new check class
cl_ehprc_check_reach_svhc_o5a

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Verify Configuration Changes (2/3) Standard Program Flow during SVHC
Check execution after applying the note
Standard EU REACH-SVHC Check

4
3

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Verify Configuration Changes (3/3)
Standard EU REACH-SVHC Check
If you have setup customer specific checks for own or other substance list than EU REACH-
SVHC and you want to use still the existing Check against Part logic in ABAP class
cl_ehprc_check_reach_svhc, make sure to create a new customer specific Check User exit
pointing to the above class or adjust the existing Customer specific exit accordingly

Example: Assess a product regarding the presence of a substance included in the SIN List
according to the “old” check against part logic

1 2

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How to enact?
Data migration and transition phase to enact the new O5A paradigm
How to roll-out the REACH-SVHC change
2 Streams – In-House Solution and Roll-Out to Supplier base
Report
R_EHPRC_MIGRATE_REACH_CLASSIFI

Prepare Enact Migrate Follow Up

Prevent user and system from executing

• Deactivate Jobs for • Apply the SAP Note • Execute report to • Activate Job for ACP compliance checks for the affected regulatory
ACP Check 2386161 initialize the new Check execution lists, such as the EU REACH candidate list or
EU REACH Authorization list
Execution • Execute and verify classification code • Continue with normal
• Stop transferring manual pre and post for an Article BOM transfer again
new BOM’s installation steps according to EU
REACH
• Verify existing In-
Process Revisions
and manual
declarations

Inform Suppliers regarding O5A Transition Period for Suppliers Import Supplier Declaration O5A

• Drive Campaign to inform Supply Chain • Provide enough lead time for suppliers to • Process Supplier Declarations according
about the new Article Definition (O5A) enact O5A and provide the updated to the new O5A paradigm
and ask for declaration updates compliance declaration
• Ideally together with an update of the EU
REACH Candidate List

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Migration Report R_EHPRC_MIGRATE_REACH_CLASSIFI

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Migration of existing Compliance Information for Supplier Parts

• Pure Substance Composition

Full Material • BOM / Input Composition Recalculated
Declaration • External FMD from Supplier

Declarable • Calculated Recalculated

Substance
List

Declarable • Manual (overwritten)

Substance
List Copy /
Reuse DSL
Declarable • Imported
Substance
List

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How to roll-out the REACH-SVHC change
Initial/Current Status for the Compliance Requirement EU REACH-SVHC
Example Structure Weight Comment REACH-SVHC Before • Example Product Structure
P 200 g Product 0,1 % SVHC-1 in P
0,2 % SVHC-2 in P with released revisions for
0,01 % SVHC-3 in P
0,15 % SVHC-4 in P
Compliance Requirement EU
10 x PP 1g Purchase Part 20 % SVHC-1 in PP REACH-SVHC
2 % SVHC-2 in PP
I-1000/Inno FMD with 20 % SVHC-1 20 % SVHC-1 in I-1000
Electronics • Due to the dilution effect
U-1000/Uni DSL or Statement Not Not Above Threshold only the following
Electronics Above Threshold
C-1000/Cable 2 % SVHC-2 2 % SVHC-2 in C-1000
substances are reported:
Incorporated
• 0,2 % SVHC-2 in P
2 x DC 10 g Designed Component 1 % SVHC-2 in DC
• 0,15 % SVHC-4 in P
10% M1 10 % SVHC-2 in Basic 10 % SVHC-2 in M1
Material M1
90% M2 No SVHC in Basic
Material M2
1 x LC 10 g 2 % SVHC-1 in a Leaf 0,2 % SVHC-3 in LC
Component
1 x SF 2g 15 % SVHC-3 in a 15 % SVHC-4 in SF
Surface treatment of P
1xB 158 g No SVHC contained in B

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How to roll-out the REACH-SVHC change
Result after execution of the Migration and ACP Check Program
Example Structure Weight Comment REACH-SVHC Before Classification ACP 2 REACH-SVHC (O5A)
1 Entries 3
P 200 g Product 0,1 % SVHC-1 in P Article X 20 % SVHC-1 in PP
0,2 % SVHC-2 in P 2 % SVHC-2 in PP
0,01 % SVHC-3 in P 1 % SVHC-2 in DC
0,15 % SVHC-4 in P 0,2 % SVHC-3 in LC
0,15 % SVHC-4 in P
10 x PP 1g Purchase Part 20 % SVHC-1 in PP Article X 20 % SVHC-1 in PP
2 % SVHC-2 in PP 2 % SVHC-2 in PP
I-1000/Inno FMD with 20 % SVHC-1 20 % SVHC-1 in I-1000 Article X 20 % SVHC-1 in I-1000
Electronics
U-1000/Uni DSL or Statement Not Above Threshold Not Above Threshold Article Not Above Threshold
Electronics
C-1000/Cable 2 % SVHC-2 2 % SVHC-2 in C-1000 Article X 2 % SVHC-2 in C-1000
Incorporated
2 x DC 10 g Designed Component 1 % SVHC-2 in DC Article X 1 % SVHC-2 in DC
10% M1 10 % SVHC-2 in Basic Material M1 10 % SVHC-2 in M1 Not An Article X 10 % SVHC-2 in M1

90% M2 No SVHC in Basic Material M2 Not An Article

1 x LC 10 g 2 % SVHC-1 in a Leaf Component 0,2 % SVHC-3 in LC Article X 0,2 % SVHC-3 in LC

1 x SF 2g 15 % SVHC-3 in a Surface treatment of P 15 % SVHC-4 in SF Not An Article X 15 % SVHC-4 in SF

1xB 158 g No SVHC contained in B Article

1 2 Migration Program 3 ACP Check Execution Released Rev. X Rev. X merged and new Rev. x+1
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How to roll-out the REACH-SVHC change
Result after execution of the Migration and ACP Check Program
Example Structure Weight Comment Classificati
on
Rev. x / 20 % SVHC-1 in PP
P 200 g Product Article 0,1 % SVHC-1 in P Rev. x+1 /
Historic 2 % SVHC-2 in PP
0,2 % SVHC-2 in P Released /
1 % SVHC-2 in DC
0,01 % SVHC-3 in P In Work
0,2 % SVHC-3 in LC
0,15 % SVHC-4 in P
0,15 % SVHC-4 in P
Rev. x / 20 % SVHC-1 in PP
10 x PP 1g Purchase Part Article
Released 2 % SVHC-2 in PP
I-1000/Inno FMD with 20 % SVHC-1 Article Rev. x / 20 % SVHC-1 in I-
Electronics Released 1000
U-1000/Uni DSL or Statement Not Above Article Rev. x / Not Above Threshold
Electronics Threshold Released
C-1000/Cable 2 % SVHC-2 Article Rev. x / 2 % SVHC-2 in C-
Incorporated Released 1000
Rev. x /
2 x DC 10 g Designed Component Article 1 % SVHC-2 in DC
Released
10% M1 10 % SVHC-2 in Basic Material M1 Not An Rev. x / 10 % SVHC-2 in M1
Article Released
90% M2 No SVHC in Basic Material M2 Not An
Article
1 x LC 10 g 2 % SVHC-1 in a Leaf Component Article Rev. x / 0,2 % SVHC-3 in LC
Released
1 x SF 2g 15 % SVHC-3 in a Surface Not An Rev. x / 15 % SVHC-4 in SF
treatment of P Article Released

1xB 158 g No SVHC contained in B Article

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Thank you
Contact information:

Kristian Mitic
Product Manager

SAP SE Dornierstr. 3, 88677 Markdorf, Germany

T +49 75 4497-0342, E [email protected]
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In particular, SAP SE or its affiliated companies have no obligation to pursue any course of business outlined in this document or any related presentation, or to develop
or release any functionality mentioned therein. This document, or any related presentation, and SAP SE’s or its affiliated companies’ strategy and possible future
developments, products, and/or platform directions and functionality are all subject to change and may be changed by SAP SE or its affiliated companies at any time
for any reason without notice. The information in this document is not a commitment, promise, or legal obligation to deliver any material, code, or functionality. All forward-
looking statements are subject to various risks and uncertainties that could cause actual results to differ materially from expectations. Readers are cautioned not to place
undue reliance on these forward-looking statements, which speak only as of their dates, and they should not be relied upon in making purchasing decisions.

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