Categorization of Products as Articles

[Michael_Mulder]

When you create a product, you can specify the product category. Until now, you had the choice between Mixture and Substance. Now, you also have the option Article. There are many dangerous substances (from lead to cadmium, nickel, or phthalates) which are found in common consumer products (like toys, jewelry, or yoga mats) and when those products are found to be non-compliant with current regulations, those products must be pulled from the market at significant costs.

The REACH Regulation defines an article as “an object which during production is given a special shape, surface or design which determines its function to a greater degree than its chemical composition”.

A core principle of the Classification, Labelling and Packaging Regulation is the 'self-classification' of a substance or mixture (and now article) by the manufacturer, importer or downstream user.

Under some circumstances, article importers have to register or notify substances in articles to ECHA (see Article 7 of REACH): these obligations are in general the same as for producers of articles. When placing articles on the market in the EEA, importers of articles may also have to communicate information on substances in their articles to their customers.

This self-classification aims to determine whether a chemical substance or mixture has physical, health and/or environmental hazards and to properly communicate these hazards with appropriate labelling in the supply chain when the product is placed on the market, regardless of the volume of the substance or mixture produced. Now we can integrate this information into product marketability, to ensure compliance for transporting and sales of such products.

The specified product categorization is maintained and displayed in the Manage Basic Compliance Data - Unpackaged Products or Manage Basic Compliance Data - Raw Materials app.

When we create a new unpackaged product or raw material, Article is now an option under Product Categorization.

When we edit an existing unpackaged product or raw material, Article is now an option there as well.

We can see product categorization status in the header when looking at the basic compliance data.

Previously, the categorization was done in the Manage Analytical Composition app.

If a different product categorization is required for a specific legal area, the product categorization can be overwritten as a part of the legal-area-specific analytical composition.

[MarkoLange]

This is a great improvement for SAP S/4HANA product compliance component. Thanks for sharing. However, important to understand that article is a material category you could have maintained already in S/4 but now product compliance part is taking this into consideration as well.

[Michael_Mulder]

Thanks @MarkoLange for the clarification. 

[christoph_bergemann]

Hello

more important is to understand "What is an article"? (from legal content perspective)? And after getting some insight.. why is it a good idea to handle this in "Product Compliance"..

On long term: may be we need as well something like "Multi Component Set".

If you read the legislation (e.g. REACh) you will find lot of chapters regarding "definitions" and what is "in scope" and what is "out of scope" (e.g. an "Article" is out of scope of REACh). But clearly: in most of the cases an "Article" contains "Chemistry" and under some circumstances the chemistry might get in touch with the human or the environment.

Therefore: even you can donefine something as an "article".. it still represents a chemistry. So it is a good idea to describe the chemistry for the case you need the information using "Product Compliance".

Different to that is the "Multi Component Set". Here we can define these simple types:

a "combined" (one physical object) material or a materia having a least two seperate physical components.

A good example is a "two component glue". You can sell the components seperate, e.g. in one box (together) or you can combine them in one physical unit.

Especially the last one might be a challenge (especially from dangerous goods point of view).

I hope that SAP will provide a good solution for the "Multi Component Set" in the next releases to come as there is a clear need to get such a support in the Software.

EHS Classic is as well not 100% tuned to work with a "Multi Component Set" (e.g. problem with Dangerous Goods handling is the reason, problem with Safety Data Sheet etc. etc.)

So I hope that you can confirm that SAP is working on "multi component set" solution using "Product Compliance" (to make this software better than EHS Classic (get better solution here)

C.B.

[Michael_Mulder]

@Christoph_bergemann Thanks for your thoughts, I was ill on Friday and unable to respond then. I will keep your comments in mind when I communicate new features. 

As far as new features coming to product compliance, on the product roadmap you can see 2 items that I believe address your multi component set in the product vision, first would be the support of kit products that contain 2 or more dangerous goods. The second would be defining customer specific dangerous goods description templates.  

The REACH Regulation defines an article as “an object which during production is given a special shape, surface or design which determines its function to a greater degree than its chemical composition”.

A core principle of the Classification, Labelling and Packaging Regulation is the 'self-classification' of a substance or mixture (and now article) by the manufacturer, importer or downstream user.

Under some circumstances, article importers have to register or notify substances in articles to ECHA (see Article 7 of REACH): these obligations are in general the same as for producers of articles. When placing articles on the market in the EEA, importers of articles may also have to communicate information on substances in their articles to their customers.

This self-classification aims to determine whether a chemical substance or mixture has physical, health and/or environmental hazards and to properly communicate these hazards with appropriate labelling in the supply chain when the product is placed on the market, regardless of the volume of the substance or mixture produced. Now we can integrate this information into product marketability, to ensure compliance for transporting and sales of such products.

I hope this helps and I appreciate the feedback

[christoph_bergemann]

Hello

Thanks for your feedback. We know: it is a hard work to get a full new "Product Compliance" solution looking on all the other modules to consider (as SAP SD, SAP MM, SAP TM, SAP eWM etc.).

According to current understanding of SAP Roadmap: yes: we will still have one place for the data. This is good !! (the CCI). And this data will be "shared" to the other processes etc. And the "Product Compliance" soluton will get (by correct set up) automatically an update (in the future) if "content" is changing.

And luckily: SAP is here on a good track (with the SAP partners) not only to deliver the "legal" part but "phrases" (and translation); new "compliance requirements" (or new version of a requirement) etc. automatically (according to my understanding: not all of the option are now available: but some will come later).

We have to wait now what will come exactly with on premise version 2025 (and later 2027 etc.).

Most interest is not only on the topic as listed above... topics like:

- Rulesets

- How Safety Data Sheet will be generated

and man other stuff is of interest as well

I hope that SAP will provide niece and easily to be extended "Analytics" solutions... currently people are always claiming. EHS Classic is "so slow" to analyze data.. so the analysis is done "outside" of SAP.

But this requires big data streams from SAP to Non SAP solution (and interesting.. many receiving software/hardware combination) has huge problems with the EHS classic data (performance etc.)

I hope: with the final solution we need not to extract the data but the analysis is done in HANA based environment.

Something which is as well of "highest" interest is the "what will happen if" scenario (there is huge interest here in sich features!)

Example: e.g. on listed substance one get an update in GHS Classification/Labeling (of one "Listed Substance" > now we need to determine: which object is potentially effected by this change and then which object is "really efffected" by his change? and what exactly is the impact?

Using EHS Classic: such analysis is nearly not possible (Performance !). The "best" you can to is to use the EHS Classic "regeneration option" of SDS to check: is there some "relevance" to generate a new SDS?  but we stopped to investigate here because of performance trouble.

I hope that the new solution (because of new data model and HANA driven architecture) can help here.

But we need to wait. Until now: we do not have any follow up solution of "Expert Server" solution.

And ideally... from company perspective: most of the stuff should be done "automatically" (on long term: i would expect to get some "Fiori Apps" listing a list of "CCI" who needs some "updates" somethere (e.g. SDS, DG etc.) to be approved by an user.

Add clearly: there is big investment needed by SAP to get such a solution; in interim: we need to check the progress by checking "cloud solution" as for "on premise".. we need to wait until roughly november 2025 to get a new released major version

C.B.