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PCB007-Sept2019

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66 PCB007 MAGAZINE I SEPTEMBER 2019 the data exchange standards—both formats and lists—to ease their reporting at low cost. Even for a simple three-component assembly, without any tools, it could cost much time to manage a request received from a customer, cascade them to suppliers, collect their dec- larations, and remind them and/or escalate them if there is no answer, roll up all declara- tions to establish the product declaration, send back declaration to the customer, and wait for their approval to close the initial request. Figure 13 shows an example process for re- questing/collecting substance declaration for a simple product BOM of four components) and a breather tube (BT01) manufactured by a Tier 3 company in the U.S. supplied to the EU. Few tools are used today for requesting col- lecting, rolling-up, and checking the declara- tions; for instance, IMDS and CAMDS as stan- dard tools for the automotive sector. Those tools should also interact with ERP and PLM systems; bottom-up data collection is usually well supported for such interfaces but not top- down from ERP and PLM to dedicated tools to manage declaration requests that are, most of the time, implemented with email notifications. While the tools are in place for declaration exchange, the next step is to connect them to sources of the data lists (the RSL/DSL or the QL authorities' information systems). It is a pity today to be aware that all existing lists and their data (substance categories, applica- tions, exemptions) getting regulatory news or data updates are a manual process or a service by data providers. To reduce the burden for companies, legal authorities and other sectorial list authorities like trade associations would have to provide web services, or similar services, to automatize these activities with system-to-system commu- nication: • Subscription services to get information on new data list availability or new regula- tion updates • Web services to get their substance lists and other data related to these lists: sub- stance classifications, materials classifica- tions, exemptions, applications, use de- scriptors (like the ones defined by ECHA) Standard tool providers should also offer several ways for supplier companies to provide their declarations: Figure 13: Declaration collection process for a simple product.

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