CDX WEBINAR ON SCIP #1 - SCIP INTRODUCTION - MARCUS SCHNEIDER 2020, FEB 26TH - FEBRUARY 26, 2020

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CDX WEBINAR ON SCIP #1 - SCIP INTRODUCTION - MARCUS SCHNEIDER 2020, FEB 26TH - FEBRUARY 26, 2020
February 26, 2020

CDX Webinar on SCiP
#1 – SCiP Introduction
Marcus Schneider
2020, Feb 26th

© 2020 DXC Technology Company. All rights reserved.
CDX WEBINAR ON SCIP #1 - SCIP INTRODUCTION - MARCUS SCHNEIDER 2020, FEB 26TH - FEBRUARY 26, 2020
Disclaimer

DXC makes no representations or warranties about the accuracy or suitability of any
information in the webinars and related materials; all such content is provided on an “as is”
basis. DXC HEREBY DISCLAIMS ALL WARRANTIES REGARDING THE CONTENTS OF
THESE MATERIALS, INCLUDING WITHOUT LIMITATION ALL WARRANTIES OF TITLE, NON-
INFRINGEMENT, MERCHANTABILITY, AND FITNESS FOR A PARTICULAR PURPOSE.
DXC hereby disclaims all liability for any claims, losses, or damages in connection with use
or application of these materials. DXC does not guarantee, warrant, or endorse the products
or services of any firm, organization, or person, other than its own. The information
contained in these webinars and related materials has been prepared, compiled, or provided
by DXC as a service to its customers and is not intended to constitute legal advice or the
rendering of legal, consulting, or other professional services of any kind.
Users of these materials should not in any manner rely upon or construe the information or
resource materials in these materials as legal, or other professional advice and should not
act or fail to act based upon the information in these materials without seeking the services
of a competent legal or other professional.

                                         © 2020 DXC Technology Company. All rights reserved.    February 26, 2020   2
CDX WEBINAR ON SCIP #1 - SCIP INTRODUCTION - MARCUS SCHNEIDER 2020, FEB 26TH - FEBRUARY 26, 2020
Who is talking to you

Marcus Schneider
Senior Consultant
DXC.technology
•   Responsible industries contact aviation,
    shipbuilding, plastics
•   20 years as a consultant with DXC (then EDS,
    HP(E))
•   Focus on compliance & sustainability information
    management in the supply chain
•   Background in software development, architecture
    and B2B integration

This webinar will be recorded.

                          © 2020 DXC Technology Company. All rights reserved.   February 26, 2020   3
CDX WEBINAR ON SCIP #1 - SCIP INTRODUCTION - MARCUS SCHNEIDER 2020, FEB 26TH - FEBRUARY 26, 2020
What to Expect for Today‘s Session

                   © 2020 DXC Technology Company. All rights reserved.   February 26, 2020   4
CDX WEBINAR ON SCIP #1 - SCIP INTRODUCTION - MARCUS SCHNEIDER 2020, FEB 26TH - FEBRUARY 26, 2020
About DXC Technology

The world’s leading companies rely on                                                With decades of experience driving
DXC Technology to run their mission-                                                 innovation, our customers trust us to
critical systems and operations while                                                deploy our Enterprise Technology
modernizing IT, optimizing data                                                      Stack to deliver new levels of
architectures and ensuring security and                                              performance, competitiveness and
scalability across public, private and                                               customer experience.
hybrid clouds.

                                   © 2020 DXC Technology Company. All rights reserved.                        February 26, 2020   5
CDX WEBINAR ON SCIP #1 - SCIP INTRODUCTION - MARCUS SCHNEIDER 2020, FEB 26TH - FEBRUARY 26, 2020
DXC Technology at a glance

~$20B                         200+
                              partner network with                                    ~6,000
global IT services leader     best-of-breed partners                                  customers
                                                                                      200+ Fortune 500 companies

60+
years of innovation
                              ~138,000                                                #122
                              employees worldwide                                     in the 2019 Fortune 500
delivering mission-critical
systems for customers

100
earned top score: 2019
                              70+                                                     10,000+
                              countries                                               Agile/DevOps
Disability Equality Index                                                             professionals

                                © 2020 DXC Technology Company. All rights reserved.                                February 26, 2020   6
CDX WEBINAR ON SCIP #1 - SCIP INTRODUCTION - MARCUS SCHNEIDER 2020, FEB 26TH - FEBRUARY 26, 2020
Creating value across the stack

                                     •    Organizations want to modernize their IT and analytics
                                          capabilities to unlock new insights, create revenue and drive
                                          efficiencies.
                                     •    DXC makes customer information more visible and actionable
                                          across functions.
                                     •    Our Enterprise Technology Stack allows customers to drive
                                          business transformation and accelerate growth.
                                     •    We help customers determine where workloads are best suited
                                          — and how to harvest data to generate meaningful insights.

                    © 2020 DXC Technology Company. All rights reserved.                       February 26, 2020   7
CDX WEBINAR ON SCIP #1 - SCIP INTRODUCTION - MARCUS SCHNEIDER 2020, FEB 26TH - FEBRUARY 26, 2020
Customers and industries we serve

                                  Insurance                Healthcare &                 Travel,          Banking &         Aerospace &
                                                           Life Sciences                Transportation   Capital Markets   Defense
                                                                                        & Hospitality

6,000+                            Consumer &
                                  Retail
                                                          Energy, Utilities,
                                                          Oil & Gas
                                                                                    Manufacturing &
                                                                                    Automotive
                                                                                                         Public Sector     Technology, Media &
                                                                                                                           Telecommunications

 customers around the world
 across a variety of industries

                                  © 2020 DXC Technology Company. All rights reserved.                                      February 26, 2020   8
CDX WEBINAR ON SCIP #1 - SCIP INTRODUCTION - MARCUS SCHNEIDER 2020, FEB 26TH - FEBRUARY 26, 2020
“ We inspire our people to do fantastic work for
  customers so they can grow their business.
  Our intimate knowledge of our customers’
  mission-critical systems lays the foundation for
  deriving insights from those systems that
  deliver new levels of performance,
  competitiveness and customer experiences.”

   Mike Salvino
   President and Chief Executive Officer
   DXC Technology

© 2020 DXC Technology Company. All rights reserved.   February 26, 2020   9
CDX WEBINAR ON SCIP #1 - SCIP INTRODUCTION - MARCUS SCHNEIDER 2020, FEB 26TH - FEBRUARY 26, 2020
CDX

Many regulations exist that require                                                    CDX is a swiss army knife: it covers
reporting on substances in materials                                                   many regulations; imports, exports
and/or articles. Also many tools and data                                              and converts data formats;
formats exist on the market that focus on                                              aggregates sourced data and does
these legal requirements. Only few exist                                               compliance analyses; integrates
that focus on multiple requirements. Even                                              data from and to inhouse processes
less tools and data formats exist that both
cover a wealth of regulations, support                                                 And supports the full vertical supply
many data standards, integrate into                                                    chain communication in a
inhouse processes, while covering the full                                             standardized and safe approach
supply chain communication.

                                     © 2020 DXC Technology Company. All rights reserved.                         February 26, 2020   10
New Compliance Regulations
Per Region / Year

                                                                          Regelwerke in regard to
                                                                          •   Chemicals /
                                                                              substances
                                                                          •   Packaging
                                                                          •   Batteries
                                                                          •   Waste
                                                                          •   Energy & Security

                                                                                Source:

                    © 2020 DXC Technology Company. All rights reserved.       February 26, 2020   11
Compliance and Risk
                       • Material information reduces                   •Less amendments due to adequate
                                                                         product design
                                                                                                                                Compliance
                         risk and cost in production,
                         helping to avoid material                      •Amendment risks are more likely to                     Management is part of
                         shortcomings                                    be identified
                                                                                                                                risk management in all
                                                                                                                                phases of the product
                                                                                                                                life cycle

         Design                                           Sales                                      Disposal / EOL             Compliance data must
                                                                                                                                be kept up-to-date
                                                                                                                                • If materials or
                               Production                                     Maintenance                                         suppliers change
                                                                                                                                • If regulations
                                                                                                                                  change
                                                                                                                                • If a product
                                                                                                                                  undergoes relevant
  • Material information                      •Avoidance of refusals and                      •Minimization of disposal risk      changes within its
    supports choice of
    riskless materials and
                                               warranty issues by high-value
                                               product information
                                                                                               through adequate documentation
                                                                                               and avoidance of problematic
                                                                                                                                  life-cycle
    thus lowers product                       •Strengthening of market position                substances / materials
    risks                                      by „certificates“

                                                                © 2020 DXC Technology Company. All rights reserved.                          February 26, 2020   12
What is CDX?
One process for the complete value chain!

    Request                         Tier 3                     Tier 2                                    Tier 1                         OEM

Participants provide                                                                                                         Supplier

safeguarded
                                                                                                   Supplier                  Supplier            Product
information – their
product, their                                                                                     Supplier                  Supplier
knowledge, their
responsibility!                                        Supplier                                    Supplier
                       Information
                       Aggregation                     Supplier

                         Supplier                      Supplier
                                                                                                                  Sourcing at the producer – a
                         Supplier                    Material                                                     question of risk and liability.
                                                    Composition
                         Supplier

      Report                   Tier 3                        Tier 2                                    Tier 1                      OEM

                                             © 2020 DXC Technology Company. All rights reserved.                                         February 26, 2020   13
WFD & SCiP – Setting Context

The WFD (Waste Framework Directive) of                                                 SCiP (Substances of Concern in
the EU (Directive (EU) 2018/851                                                        articles as such or in complex
amending the Waste Framework                                                           objects (Products)) serves the
Directive) is targeted at creating effective                                           purpose of the WFD to enable
policies to regulate usage of substances                                               dissemination of information on SoC
in the EEA so as to establish closed loop                                              to the recycling industries as well as
economies. As a first step, substances                                                 the end consumers in the EU,
as regulated under REACH are in focus.                                                 entitled by their right to know.
Industries shall be enabled to better                                                  Reporting duties start 5, Jan, 2021
understand and work on recyclable                                                      SCiP is mandated by WFD to ECHA,
goods, and design for sustainability…                                                  as well as establishing what is
                                                                                       “required data”

                                     © 2020 DXC Technology Company. All rights reserved.                         February 26, 2020   14
Important to Know - Policy Context

                   © 2020 DXC Technology Company. All rights reserved.   February 26, 2020   15
Important to Know - Legal Context

• Various legislations analysed and „interfaced“
  – Chemicals
  – Waste
  – Products
• Ecodesign Directive
• Upcoming reviews Packaging and Packaging Waste, ELV, Batteries Directive
LED TO
• Directive (EU) 2018/851 amending the Waste Framework Directive
  – Reinforce the waste hierarchy
  – Facilitate recovery through decontamination
  – New Article 9 on waste prevention objectives/measures, including a new ECHA database
  – Extended producer responsibility –modulation of fees

                                            © 2020 DXC Technology Company. All rights reserved.   February 26, 2020   16
SCiP and ECHA‘s Mission

• According to §9(2) of the WFD, its purpose is
  – „To establish and maintain a database for information down in the supply chain on substances
    in articles“
  – „To provide access to the database to ‚Waste Treatment Operators‘, and to consumers (upon
    request)“

• This activity has been mandated to ECHA, including the needed definition of „what is required“ to
  – Enable submission on articles and contained substances
  – Disseminate information, so that the purpose of the directive can be adhered to
    (RECYLABILITY)

• This leads to a situation, where „what is required“ exceeds requirements from REACH §33

                                           © 2020 DXC Technology Company. All rights reserved.        February 26, 2020   17
SCiP in Detail

SCiP is about collecting information on                                               Although it is stated that the initial
substances of concern in articles                                                     scope is REACH §33, this is not an
respectively products containing articles.                                            exact reflection on the requirements.
While the initial scope is enforcement of                                             Substances from the candidate list,
REACH §33 reporting, it is important to                                               the 0.1% threshold, the article
understand, that WFD does not talk about                                              definition are all derived from §33,
SVCH, but SoC – which will include in                                                 but there is data beyond, as
future iterations reporting of scarce                                                 envisioned by ECHA.
materials, plastics in regard to their
recyclability quota etc. etc.

                                    © 2020 DXC Technology Company. All rights reserved.                         February 26, 2020   18
SCIP planned timeline

                         IUCLID
                         Format
                         publication
                         • 1st IT User
                                                                                                    Legal                       SCIP
 Initial Q&A and                                            Prototype
                           group WebEx                                                          requirements                 submission
 public material                                             release
                         • Workshop open                                                        into local law               version 1.0
                           to all

                   CDX      Planning & preparation     Implementation & testing         Customer involvement   Initial production release

                                          © 2020 DXC Technology Company. All rights reserved.                                       February 26, 2020   19
SCiP – Process view

  Provide their
  ECHA API key for
  S2S authentication
  CDX will support scenario, provide
  minimum required information. Technical
  details partly published by ECHA

                                            © 2020 DXC Technology Company. All rights reserved.   February 26, 2020   20
SCiP – What to Report

                                                                         ECHA requires Material Categories,
                                                                            which are not part of §33 – and
                                                                                ECHA introduces a new
                                                                          categorization scheme that can not
                                                                         be fully mapped to existing schemes

                              No Soc, no report duties. Only those
                                articles within complex products         • Every produced
                              must be reported that contain SoC.           permutation of a product,
                               There is no need for intermediate           no „150%“ declaration,
                                            structures.                    covering variances.
                                                                         • Family reports possible, if
                                The wheel levels are optional, as          „the same“ in regard to
                               they not directly contain SoC. Only         reportable content
                               the O-rings are mandatory, as they
                                          are the article!

                   © 2020 DXC Technology Company. All rights reserved.                      February 26, 2020   21
SCiP – Dossier

                                                                                     IUCLID
                                                                                     Dossier

                             Article                 Safe use          +   Concern
                          Identifications
                                             +      instructions           element

                 © 2020 DXC Technology Company. All rights reserved.                 February 26, 2020   22
SCiP – Identifying Articles

▪Article name                                                              ▪ Article category: TARIC/CN code
                                                                             + description
▪Other names                                                                  (TARIC list)
▪Brand*
▪ Model*
                                                                                                  73181582 - Base metals and articles of base metal >
▪ Type*                                                                                           Articles of iron or steel > Screws, bolts, nuts, coach
                                                                                                  screws, screw hooks, rivets, cotters, cotter pins,
                                                                                                  washers (including spring washers) and similar
                                                                                                  articles, of iron or steel > Threaded articles > Other
                      If an article is a consumer good, the                                       screws and bolts, whether or not with their nuts or
                   additional identifiers might be required for                                   washers > Other > With heads > Hexagonal heads >
                                    identification                                                Other, with a tensile strength > Of less than 800 MPa
                                                                  https://ec.europa.eu/taxation_customs/business/calculation-customs-duties/what-is-common-customs-tariff/taric_en

                                                                              This information is required. The nomenclature is an up to 5-
Information from                                                             level nested picklist of about 16.000 entry codes + exhaustive
Oct, 1st 2019                                                                                           description

                                                         © 2020 DXC Technology Company. All rights reserved.                                              February 26, 2020   23
Introduced to CDX – Picking Article Categories

                                                                          Soon to be
                                                                          expected in
                                                                             CDX

                    © 2020 DXC Technology Company. All rights reserved.          February 26, 2020   24
Identifiers
(numeric or alphanumeric)

▪ECHA Article ID
▪GTIN (Global Trade Item Number)
▪EAN (European Article Number)*
▪GPC (Universal Product Code)
▪JAN (Japanese Article Number)
▪UDI (Unique Device Identification)
▪ISBN (Int. Standard Book Number)
▪Catalogue Number
▪Batch Number
▪Part Number                                                                         One primary identifier is required – for end-
Information from                                                                      consumer products it is the EAN. Other
Oct, 1st 2019                                                                            identifies might be added as well

                                      © 2020 DXC Technology Company. All rights reserved.                                 February 26, 2020   25
Safe use instructions

“No need to provide
     safe use
information beyond
  identification of                                              Information that ensures the article’s safe use,
                                                              including its proper management at the waste stage
   Candidate List
                                                                                - Free text field
    substance”

                      Disassembling instructions
                            - Pdf document
 Information from
 Oct, 1st 2019

                        © 2020 DXC Technology Company. All rights reserved.                         February 26, 2020   26
Concern Element

▪Candidate list version

▪Candidate list substance

                            ECHA provides picklist of valid ranges, at least 0.1% to
▪Concentration range                         100% is required

▪Material category and/or Mixture category

                              The category scheme level 2 from ECHA does not
                             100% match existing classification schemes used in
                             the industries, i.e. in IMDS or CDX, causing massive
                                effort for repeated reporting, unless the „other“
Information from                          category might be applicable.
Oct, 1st 2019

                                            © 2020 DXC Technology Company. All rights reserved.   February 26, 2020   27
Mock Up for Submission

                                                                          The API key is
                                                                          provided by ECHA
                                                                          registration. It is
                                                                          maintained in CDX
                                                                          by the Company
                                                                          Admin, for the root
                                                                          company,
                                                                          optionally per OU,
                                                         Provide Link
                                                        to WCM (MDS       overriding
                                                          Explorer). If   predecessor
                                                        possible direct
                                                          linkt to job

                  © 2020 DXC Technology Company. All rights reserved.             February 26, 2020   28
Rules – When Checks Happen

                                                                                                             • rules CDX can not adapt from
                                                                                                               IUCLID
                                                    Contextual rules &                                       • Failure leads to discarded
                                                                                                               submission
                                                    IUCLID Checks                                            • Either get failure or
                                                                                                               submission ID back to CDX

                                                                                      • CDX to adapt as possible rules that pertain to
                                                                                        IUCLID dossier
                                                                                      • Failure leads to discarded dossier submission
                                   IUCLID Rules

                                           • Rules that pertain to CDX reporting and compliance validation
                                           • Only released MDSes may be submittedno direct
                                           • No direct submission of received MDSes
             CDX Validations

                     © 2020 DXC Technology Company. All rights reserved.                                                                      February 26, 2020   29
Questions?

             © 2020 DXC Technology Company. All rights reserved.   February 26, 2020   30
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