SCIP – visibility over hazardous chemicals in products

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SCIP – visibility over hazardous chemicals in products

On September 14, 2021, the new SCIP Dissemination Portal by the European Chemicals Agency (ECHA) went live, giving the public access to information about substances of concern (SVHC) in articles as such or in complex objects (Products). The portal’s launch increases the transparency over chemicals of concern in products and will help track products containing substances of very high concern until they reach the waste stage. It also allows consumers to make more informed purchasing decisions and to choose safer products.

Since January 2021, companies that supply articles containing substances of very high concern (SVHC) on the Candidate List in a concentration above 0.1% weight by weight (w/w) in the EU market have been required to submit information on these articles to the ECHA. The notifications are stored in the SCIP (Substances of Concern in Products) database, and will be publicly available via the portal throughout the entire lifecycle of the products and materials – including the waste stage – contributing to a safer circular economy.

In a recent announcement, the ECHA said that around 6,000 companies across the European Union have already complied with this new obligation, with more than four million relevant article notifications registered in the SCIP database.

Based on the information gathered so far, the most notified product categories include:

  • Machinery and their parts
  • Measuring instruments and their parts
  • Electronic equipment and their parts
  • Vehicles and their parts
  • Articles made of rubber
  • Furniture. 

Who needs to submit information?

Companies that supply articles containing substances of very high concern (SVHC) on the Candidate List in a concentration above 0.1% weight by weight (w/w) in the EU market are required to submit, including:

  • EU producers and assemblers
  • EU importers
  • EU distributors of articles and other actors who place articles on the market.

Retailers and other actors that supply articles directly to consumers are not obligated to submit this information to ECHA.

What information needs to be submitted?

  • Information relevant to the identification of the article;
  • Name, concentration range, and location of the SVHC; and
  • Other information on the safe use of the article, particularly if the above information is not sufficient to ensure the proper management of the article as waste.

 Do you have any questions about how the new SCIP database requirements affect your business? 

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Germany’s new Supply Chain Due Diligence Act

Many governments around the world are using legislation to drive responsible business practices and positive impacts on people’s working conditions. These laws require companies to manage their operational impacts on people and the environment and report on their efforts. It’s important to know which of these laws apply to your business and how to comply.

One of the most recent changes in this area is the new Human Rights Due Diligence Law adopted by the German parliament on June 11, 2021.

From 2023, this law will require large companies to conduct supply chain due diligence activities. Companies will need to identify, prevent, and address human rights and environmental abuses within their own and their direct suppliers’ operations, and take actions if they find violations.

The law aims to ensure that social and environmental standards are maintained in large companies’ operations and supply chains to address the following risks:

  • Forced labor
  • Child labor
  • Discrimination
  • Violations to freedom of association
  • Unethical employment
  • Unsafe working conditions
  • Environmental degradation.

Who does this new law affect?

  • From 2023: Companies based in Germany with more than 3,000 employees, or German-registered branches of foreign companies with more than 3,000 employees.
  • From 2024: Companies based in Germany with more than 1,000 employees, or German-registered branches of foreign companies with more than 1,000 employees.

What do the affected companies need to do?

  • Set up a process to identify, assess, prevent, and remedy human rights and environmental risks and impacts in:

    1.  Your supply chain    
    2.  Your own operation.

  • Ensure you provide ways for employees of indirect suppliers to file a complaint alerting the company to any human rights or environmental violations.
  • Publish an annual report outlining the steps you have taken to identify and address these risks.

How can affected companies prepare for this change?

If this – or any similar law – applies to your business, it’s most important to have a clear internal process to understand and assess your supply chain:

Step 1: Define your scope

Map your suppliers and put in place a preliminary risk analysis to better understand your supply chain and current CSR capabilities.

Step 2: Pre-assess your suppliers’ CSR conditions

Conduct a deeper evaluation to identify your most reliable suppliers, the ones requiring action, and those with zero tolerance issues. You can then prioritize your program and create an action plan.

Step 3: Apply relevant actions based on identified risks and priorities

Deploy an adequate action plan based on the identified issues and their risk levels and implement remediation programs to improve the suppliers’ performance.

Many other countries have enhanced their regulations on human rights, such as:

  • Australia: Modern Slavery Act 2018
  • France: Corporate Duty of Vigilance Law
  • Germany: CSR Directive Implementation Act
  • India: Business Responsibility and Sustainability Reporting
  • Italy: Legislative Decree no. 254
  • United Kingdom: Modern Slavery Act 2015
  • United States: Transparency in Supply Chains Act 2012 (State of California).

How API can help you prepare for these legislative requirements:

  • Documentary review
  • Preliminary risk assessment to help you prioritize issues
  • Factory audit
  • Training
  • COC/manual/audit guidelines creation and review
  • Program benchmarking services for strategic suppliers.
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How safe is your kitchenware?

The kitchen utensils and cookware industry is highly regulated, with strict safety standards to ensure the health and safety of consumers. Chemicals present in what’s known as ‘food contact materials’ are known to potentially migrate and contaminate the food they come into contact with, creating risks for consumer health.

How can consumers therefore be sure that the container in which they are storing their food is safe? Or that the mug they are drinking coffee from is not releasing harmful chemicals? In most countries worldwide, all food contact products must comply with the applicable regulations governing the most common materials used and the product’s intended use.

The rules to follow depend on the material and country. For example, items sold in the EU and the US must comply with regulations such as the EC No. 1935/2004 in the EU or the FDA 21 CFR in the US, which cover the most common materials such as plastics, silicone and rubbers, metals and alloys, ceramics, wood, paper and board, varnishing and end coating, and more. Different criteria will apply if the container is plastic or ceramic, for instance, but also if it is intended to be used for aqueous food such as water or coffee, acidic foods like juice, or alcoholic beverages such as beer or wine, and if the container is designed for a single or repeated use.

Risks can still be identified after the products arrive on the market, even for major brands, which not only put the brand’s image at risk but can also generate additional costs if there are product recalls or fines. Some major brands were the object of product recalls last year, such as a major international furniture and décor brand that recalled a mug from the market which was potentially migrating excessive levels of dibutyl phthalate (DBP).

On top of the chemical risks, kitchen accessories have some associated physical risks related to fatigue, corrosion, and heat resistance as well as thermal hazards. They also must perform according to their expected use; for example, if they are intended to be microwave- or dishwasher-resistant, they will need to handle heat or water without breaking or suffering damage. While this may seem straightforward, physical risks are also frequently identified in the market for kitchenware articles. More common recalls include a heightened risk of injury and burns because of a container breaking under heat exposure or laceration hazards due to product cracks.

Meticulous quality checks and in-depth regulatory knowledge are critical, as well as ensuring you work with the right suppliers and maintain strict controls throughout product development and manufacturing. It is vital to understand each factory’s capacities, the origin of the materials used, and that the design is being precisely followed. To improve overall product quality, a factory audit can help you understand and optimize a factory’s capabilities, including:

  • Quality management
  • Product development 
  • Incoming quality control 
  • Production process control 
  • Finished product quality control 
  • Resources management 
  • Stock management 
  • Measuring & testing equipment control 

The kitchen utensils and accessories industry is also highly competitive. Numerous brands compete for consumer attention with constant overhauls of their range and, in many cases, a price battle. This adds further considerations to the equation, such as the importance of innovation and fit-for-use to bring products to the market that meet consumer expectations.

In this challenging environment in which supply chains are under pressure and shipping delays put delivery times at risk, ensuring product quality and safety before the end of production is key, so you ‘get it right the first time’.

API’S SPECIALIZED SOLUTIONS FOR KITCHENWARE

API helps brands and retailers ensure the safety, quality, and performance of their kitchenware with our tailor-made solutions. Some of our key areas of support include:

  • Laboratory testing: Testing according to EU/US or country-based directives to maintain chemical and physical safety as well as testing with specific protocols to ensure performance and fit-for-use.
  • Product development support: Identification of critical areas and recommendations for adjustment at the design or purchase stage.
  • Technical Compliance File: Documentary review that attests product compliance according to protocol definitions, from document collection and verification to report issuance.
  • Factory audits: Factory evaluations that assess factory capabilities to meet production standards and deliver safe products on time.
  • Dedicated programs: Bespoke programs based on each client’s needs that provide support at every stage of the supply chain.

Interested in learning more about API’s kitchenware solutions?

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0% risk of unexpected chemicals with Chem Scan Check™

Did you know that around 80% of chemicals in Asia are either produced locally or come from unknown sources? There are no guarantees that some of these chemicals don’t contain traces of hazardous substances, making your products and supply chains vulnerable. In 2020, one in four imported products were found to be non-compliant with REACH and CLP*, with most cases focused on the presence of the restricted substances cadmium, lead, and nickel.

 

While uncertainty around chemical composition can be toxic for consumer confidence in general, brands and retailers have different setups, needs, and levels of awareness regarding compliance, risk, and sustainability:

  • Some have mature testing programs in place and are responsive to existing pressures in their market. These companies would still benefit from a single test that can detect hundreds of substances with fast results, attractive pricing, strong service support, and the advantage of monitoring low-performing vendors and empowering high-performing vendors.
  • Other companies focus on finished products only, meaning that when they detect a risky substance, it’s often too late to cancel the order. Testing articles when they’re finished or late in the process may lead to reproducing the entire line of articles and retesting, which can blow out budgets.
  • Some companies have no system in place and no chemical or regulatory expertise but still want to offer the end-user a secure product. Generally speaking, all companies want to be more compliant and transparent.

 

As the use of recycled materials in products increases, the possibility of these materials containing unknown substances follows suit. Overall, better fashion begins with a bigger commitment to detect and address issues from the beginning, leading to less impact on the environment and society, empowering the best-performing suppliers, and focusing time and money on where the risks are high.

 

Our new solution: Chem Scan Check™

To support our partners in optimizing their testing strategies, we developed Chem Scan Check™ (CSC), which scans for more than 285 hazardous chemical substances in one go. Instead of waiting for a pass/fail outcome for expected chemicals with a traditional testing approach, we offer our partners insight into the potentiality of 285 chemicals that may be present—including those you wouldn’t usually look for in a regular test.

What does Chem Scan Check™ offer that’s different?

While our Worms Safety network proudly offers 15 laboratories globally for traditional testing methods, our broader goal is to enable our customers to anticipate risks, identify root causes, and instill a more innovative, proactive approach.

  • One test, 285 substances: Chem Scan Check™ brings to the market one test run instead of the full substance list test. With only 5g of material, you can receive a screening result in accordance with the AFIRM restricted substance list for your textiles or plastics within 72 hours—and at a cost level that makes sense. The innovative technology is applicable to all products containing plastics and textiles; however, our current scope focuses on textiles, apparel, footwear, and home textiles, including sensitive products such as baby wear.
  • Increased visibility for better business: As Chem Scan Check™ offers greater visibility over product lines, it is an excellent opportunity to achieve company strategies that are not restricted by common test parameters.
  • End-to-end solution: A key advantage of Chem Scan Check™ is that it’s applicable across the entire life cycle—from raw materials to semi-finished products to finished products—monitoring recycled materials and certified materials.
  • Customizable and adaptable: While it’s highly beneficial across the entire supply chain, CSC is a customizable concept that can address specific focus points, such as monitoring within a vendor empowerment program or complementing sustainability strategies with a scientific method.

 

Chem Scan Check™ in action

We have already experienced cases in which sensitive products such as baby wear passed a risk-based RSL test, but our Chem Scan Check (CSC) detected a non-compliance. In another case, CSC found prohibited chemicals—including phthalates and PAH—in rubber pet toys, which were possibly used to give the toys a flexible, plastic feel. In another instance, CSC detected exotic fertilizer (diammonium phosphate) within a teddy bear. The brand then uncovered that the new supplier they were working with was using local chemicals that contained the fertilizer.

 

Why 285 chemicals?

Chem Scan Check™ can actually check for more than 285 substances. Currently, over 500 substances are calibrated with external standards. However, while Chem Scan Check uses powerful solvents and equipment, there is a limitation to organic substances. Each substance in the screening process also needs to be validated with extensive research to ensure repeatability and accuracy, so we have initially focused on supporting the textile industry in relation to the AFIRM RSL. At the moment, Chem Scan Check™ in combination with additional tests for heavy metals and formaldehyde can cover 100% of substances listed under AFIRM.


Which chemicals are covered by Chem Scan Check™?
  • Phthalates
  • PAHs
  • Azo dyes
  • Disperse dyes
  • Short/middle-chained chlorinated paraffins
  • PCP
  • VOCs
  • Alkylphenol ethoxylates (APEOs, NPEOs, OPEO)
  • Dimethylfumarate (DMFu)
  • PFOA
  • And more

To cover completed RSL lists, other tests like heavy metals and formaldehyde will be tested separately.


How can Chem Scan Check™ (CSC) integrate with your chemical strategy?
  • Superior sustainability: CSC will complement your existing recycled materials testing, facilitating broader claims with the assurance that your products contain 0% of unexpected non-compliant substances.
  • Tighter risk control: CSC allows you to test more substances that you wouldn’t usually look for, generating greater visibility and reducing risk.
  • Test new areas: CSC can cover the entire life cycle of your products and will invite you to consider new testing areas of focus, such as raw materials.
  • Customizable for vendor empowerment: CSC enables you to award greater autonomy to your best-performing suppliers by allowing for random, limited checks instead of one-size-fits-all testing.
  • Preparedness for new regulations: CSC will ensure you are ready for new regulations that require increased visibility and control over substances that may be present in your products.

 

What are the product applications?
  • Unknown source chemicals
  • Chemical cocktails
  • Recycled materials
  • Sensitive products

 

*According to an ECHA report: https://echa.europa.eu/-/1-in-4-imported-products-found-to-be-non-compliant-with-reach-and-clp

 

Click here for more information about Chem Scan Check™.

Interested in finding out how Chem Scan Check™ can improve your chemical management performance?

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New European standards for outdoor candles

In December 2021, two new European standards for outdoor candles were published to help ensure a reasonable degree of safety during their use: “EN 17616:2021 Outdoor candles – Specification for fire safety” and “EN 17617:2021 Outdoor candles – Product safety labels.”

These documents specify requirements, testing methods, and labeling requirements for the fire safety of candles intended to be burned outdoors. The European standards will be given the status of a national standard, either by the publication of an identical text or by endorsement, by latest June 2022, and conflicting national standards will be withdrawn by latest June 2022.

The major new requirements for outdoor candles include:

Container candles

  • The candle shall not tip over when tested on a slope of 10°
  • The wind resistance shall have a value > 1
  • The temperature at the surface below the container shall not exceed 350°C
  • No secondary ignition shall occur for more than 10 seconds
  • The container shall not ignite or break during testing
  • The container shall not burn for longer than 15 seconds on average and 30 seconds in any individual test during the testing
  • The container shall not be completely burned away during testing
  • The candle shall not spontaneously relight after extinguishing 

Freestanding candles

  • The candle shall not tip over when tested on a slope of 10°
  • No secondary ignition shall occur for more than 10 seconds
  • The candle shall not spontaneously relight after extinguishing

 

Garden torches

  • Shall be designed to be set up and stay in a stable manner
  • No secondary ignition shall occur for more than 10 seconds
  • No burning or smoldering material shall fall off during testing
  • Candles placed on a stick shall also meet the requirements relevant for the respective candle type, except stability

 

Floating candles

  • No secondary ignition shall occur for more than 10 seconds
  • The candle shall not spontaneously relight after extinguishing


Mandatory supplementary safety information (symbols or text)

  • For outdoor use only.
  • Never leave a burning candle unattended.
  • Keep a distance of min. x m beside and y m above to things that can catch fire.
  • Keep away from children and pets.
  • Use a heat-resistant base. (Not mandatory if the container itself has a heat-resistant base)
  • Candle gets lighter during burning, protect from strong wind by using a suitable holder.” (For container candles that didn’t comply with the wind resistance requirement as specified in EN 17616)
  • Only use at cemeteries outdoors. (For grave lights only)
  • Use in a suitable bowl filled with water. (For Floating candles only)

Layout of the product safety label:


At API, we can support our customers to comply with these or other requirements for candles to further secure the safety and quality of your products.

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5 steps for importing furniture with smoother sourcing

With unprecedented quality issues facing the importing of furniture, how can we avoid lengthy delays, product recalls, and brand reputation damage before it’s too late?

Southeast Asia remains a hub for furniture imports, despite logistics, compliance, and communication barriers posing continuous challenges. Pressures stemming from COVID-19 haven’t helped, leading to brands being unable to visit their factories, shipment delays requiring more flexible and agile manufacturing, and last-minute surprises like raw materials and component shortages.

All these can put product safety and quality at risk, but following a few key steps can ensure your furniture reaches you at its optimum quality to protect your competitive advantage and meet the standards of your market destination:

1. Determine your defect classification list

This step is often an afterthought, but classifying your defects at the outset will help clarify the meaning of your furniture inspection reports.

This is the most widely used defect classification list (DCL):

Critical defect – A defect that judgment and experience indicate is likely to:

  • Result in unsafe conditions for individuals using, maintaining, or depending upon the products; or
  • Prevent performance of the tactical function of a major end item. A critical defective is a unit of product that contains one or more critical defects.

Major defect – A defect that is likely to result in failure or reduce the usability of the product for its intended purpose.

Minor defect – A defect that is not likely to reduce the usability of the product for its intended purpose or is a departure from established standards having little bearing on the effectiveness or operation of the product.

If there is no established DCL, API offers a detailed inspection checklist to proceed with the inspection.

2. Conduct an inspection during production or place a dedicated technician onsite

This is a critical stage in ensuring that your final piece of furniture reaches its expected level of quality. It allows you to identify problems before the end of production and to adopt the required corrective measures to improve results along the production line.

3. Update your furniture specifications based on in-production feedback

Consider critical areas for improvement and the points that need to be addressed, and put a strategy in place to correct them. At this stage, you will need to re-communicate your product specifications to the factory, which may bring language challenges when sourcing in Asia. You can overcome these barriers by using a neutral third-party quality provider with expertise in your sourcing area. This ‘boots on the ground’ approach will ensure that your product specifications are communicated correctly and clearly.

4. Do a root cause analysis as a preventative measure

It is important to have a root cause analysis (RCA) strategy that determines how you will handle any defective products with your supplier. This need not be a time-consuming strategy; it should simply highlight potential problem areas and make room for process optimizations.

Don’t have an RCA strategy? Follow these steps:

  • Recognize and define the problem – Acknowledge and define your furniture’s production issue.
  • Identify the causes – Go through the process of cause identification. The trick here is not to spend too much time brainstorming or mind mapping. This needn’t be a time-consuming part of the root cause analysis.
  • Identify the solutions – Based on your cause identification, you will need to determine the best possible solutions for addressing the problem to avoid it happening again.
  • Implement the solutions – If your furniture quality was compromised during the production line, you would need to begin implementing the solutions you identified to prevent future occurrences. The solution should optimize and improve your operational processes. If it doesn’t, you may need to repeat the above steps.

5. Conduct a final check with a random inspection

A final random inspection is an inspection of a small sample of your furniture prior to shipment. This is used to determine any quality defects that may have come from the production process. Questions to consider include:

  • Does the furniture sample meet all of your product specifications?
  • How many visual defects are there?
  • What onsite tests need to be done?

Key Takeaways

A clear strategy to identify risks upstream is key in producing high-quality furniture that meets customer expectations. Some of the benefits of a well-planned sourcing strategy include:

  • Improved products
  • Faster time-to-market
  • Quality budget optimization
  • Increased customer satisfaction.

The above steps should be planned and strategized for each product category that you source. At API, we support our customers with solutions all along their supply chains. Contact us now to learn more about how our furniture expertise can give your brand the competitive edge it deserves.

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API at ICPHSO Annual Meeting and Training Symposium 2022

API is glad to be participating as a sponsor at the 2022 ICPHSO Annual Meeting and Training Symposium. The event will take place on February 14–17, 2022 in Washington, D.C. The four-day Annual Meeting and Training Symposium provides an opportunity for global health and safety professionals to participate in discussions that further enhance the safety of consumer products throughout the world.

Will you also attend the event? Book an appointment to talk to our team!

Visit ICPHSO’s website for more details about the event: https://icphso.org/ 

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