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74 DESIGN007 MAGAZINE I NOVEMBER 2021 Rather, I want to look at one of the chief cost-burdens associated with complying with these regulations, specifically the cost of obtaining and communicating materials infor- mation throughout the supply chain. As an example, let us consider the new reporting obligations associated with the Euro- pean Chemicals Agency's (ECHA) substances of concern in articles as such, or in complex objects (products) (SCIP) database. In brief, the European Union (EU) Directive 2008/98/ EC on Waste, commonly referred to as the EU Waste Framework Directive (WFD), entered into force in July 2018. e WFD set require- ments on waste management, recycling, and recovery of products manufactured in, sup- plied to, or imported to the European Eco- nomic Area. As part of these requirements, the WFD mandates that any article containing substances of very high concern (SVHCs) must be declared to the ECHA so that this informa- tion can be made available to waste operators and consumers. e database is now live with more than four million submissions available for review. (Whew!) Even more, if your product contains a can- didate list substance and you would like to manufacture or sell it in the EU, you have to notify ECHA and declare whether any of those candidate list substances are below threshold. As I indicated, almost every engineer has heard of RoHS, and most have probably heard of REACH. But if you are not a compliance manager, or in some other kind of purchasing or procurement role where you are exposed to the immensity of your supply chain, you may not be aware of how onerous determin- ing whether your product contains SVHCs (let alone their positions in product, percentage of total mass and whether they are above thresh- old, etc.) can be. Let's look at an example specific to the SCIP database, keeping in mind that I am mak- ing this as absolutely generic as I possibly can. Consider hypothetical Company A is an OEM producing inexpensive, low-complexity phones. In fact, these phones are so low-com- plexity, that Company A has only two suppli- ers—Company B and Company C. Now, Company A is based in Canada but would like to sell into the EU. ey find a dis- tributor in Germany who will provide to con- venience stores there and in a few neighboring countries. On top of other bureaucratic neces- sities—too many to name here—Company A learns that they may have obligations to report to ECHA. A representative from Company A contacts Company B and C and asks them to provide chemicals information on their products. As it turns out, Company B's supplier stream is a bit wider, and now they have to contact their sup- pliers—all 10 of them—to ensure their chemi- cals composition, and onward and upward the pipeline. Company C, feeling proud of their proactivity, provides Company A with an Excel sheet containing candidate list substances (and a few others for good measure). Of course, the information does not satisfy all requirements needed for SCIP; you get the idea. Oh, and when Company B does get back to Company A a few months later, they hand over a PDF report. What is critical in this overly cartoonish example is that there are real humans perform- ing real work to support every action verb in the above paragraph. Consider the very real complexity of your supply chain, even if you are not a tier one company, and you can under- stand how complying with even one global regulation can add to your costs. The database is now live with more than four million submissions available for review. (Whew!)

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