When compliance is considered from the beginning, executives have better insights into risks such as revenue impact, product exemptions, supply chain exposure, inventory vulnerability and the useful life of a particular product. To mitigate corporate risk and have the maximum number of options at minimal cost, an effective product stewardship program begins with product compliance at each stage of the product lifecycle (Figure 2). So, let's now look at these stages.
CONCEPT AND DESIGN
Incorporating product compliance early in the product lifecycle will help a company design more-sustainable and eco-friendly products without increased cost or time to market by ensuring it designs in approved chemical substances from the start. Providing cross-organizational access to a vast and current regulatory-knowledge base and toxicological data standardizes the way product design teams gather and analyze compliance information across business divisions, product lines and geographically distributed teams, enabling more organizational agility during the concept and design process.
At this stage, a company must identify any global regulatory constraints. It must assess raw materials for formulations and identify appropriate labeling requirements. Rules-based compliance screening helps avoid costly last-minute reformulation or repackaging of products by understanding the regulatory business risks associated with material composition based on the intended use. The firm also must create a detailed plan for disposal and end-of-product use.
One of the biggest challenges facing a company at this stage is that product stewardship regulations and standards are changing at an unprecedented rate.
Tips to help keep up with the accelerated pace of change:
• Ensure all data collected and documents developed are in a standard, auditable format. That way any information captured can be re-used in other formats as requirements evolve.
• Develop IT systems that are standardized, flexible and on-demand so that investments are preserved.
• Resist a "not invented here" and "we are unique" attitude. Be open to outsourcing to a specialist in regulatory compliance.
SOURCING AND PROCUREMENT
Once a product has been conceptualized and designed, a company must be able to source sustainable and compliant raw materials from suppliers. For each raw material, important information on composition must be identified to support regulatory requirements.
More specifically, REACH legislation requires manufacturers and importers to have a thorough knowledge of every substance used in the manufacture of an article or preparation. This means the manufacturer must know whether its upstream suppliers have registered or intend to register any substance subject to REACH used in quantities exceeding 1 ton/yr.
A company must enable collaboration between procurement and regulatory teams by implementing compliance-based purchasing workflow as well as continually monitor, assess and manage supplier risk. By leveraging a central collaboration portal, a procurement organization can gain better visibility and control over supplier and raw material data, and reduce operational costs by automating the process of capturing supplier information.
A supplier should provide a "Full Material Declaration" during the procurement process. However, the reality is that many are reluctant to disclose the information for a variety of reasons -- it's not readily available, volumes are low, or they lack the financial or people resources to produce the information until a key customer demands it.