In order to encourage substitution of Substances of Very High Concern (SVHCs) with safer alternatives, enable consumers to make better informed purchasing decisions, and provide information on how to best dispose of affected products, the European Union introduced regulations for greater product transparency in 2021. To be compliant and also support our customers in responding to the new regulation, we have invested in digitizing data processes.
As of early 2021, components with SVHCs in a concentration above a set threshold, which are imported or sold in the European Union, must be reported in the so-called SCIP Database, created by the European Chemical Agency. Working together with internal stakeholders, a global taskforce was setup to develop data collection and reporting processes for the European market through the iPoint SCIP Database Connector tool.
As a first step, we assessed our top-selling products in the European Union affected by the SCIP database reporting requirement. We then identified – for each product type – the “worst case scenario” of the product’s Bill of Materials, meaning all possible accessories, materials and combinations of manufacturing part numbers were included for further assessment. The newly developed LCA Tool and the Environmental Product Declarations (EPDs) were the key resources for the analysis. Finally, we created the dossier data and submitted them to the central database. Currently, we have entered 25 dossiers of our top-selling products and now we are continuing with further products.
During the assessment, we took a particular focus on metal alloys containing lead, which is a known SVHC. Lead is normally alloyed with other metals to improve their mechanical properties, which allow machining and cutting and thus play a key role in our production processes and in the quality of our finished products. It is challenging to subsitute its use. But, together with a university partner and members of our internal Material Compliance Network, we are continuously searching for solutions to reduce the lead content in our products without compromising their quality. As members of the ARGE (European Federation of Associations of Locks and Builders Hardware Manufacturers), we also take an active part in industry-wide discussions on potential ways to reduce the lead content in locks and keys.