Having companies submit notifications to the ECHA SCIP database about articles that contain substances of very high concern (SVHC) fulfills one part of the overall goal of the Waste Framework Directive. Through the collection of data via the SCIP database, authorities can monitor the use of SVHCs and take appropriate measures if they wish. In addition to that, the information provided to the SCIP database will be publicly accessible through the SCIP dissemination portal or platform.
Why? It is part of the European Green Deal where the European Commission adopted the Circular Economy Action Plan. The Waste Framework Directive (WFD) was founded as one of the steps to moving towards a sustainable future. The vision for this is to transform from a linear model of production and consumption to a circular one, as depicted in the image below. Hence, data submitted to the SCIP database will be accessible through a platform to complete the information loop.
📑To recap, the SCIP database was established to serve the following objectives:
- Decrease the generation of waste containing hazardous substances
- Make information available to improve waste treatment operations
- Allow authorities to monitor the use of hazardous substances
- Enable informed purchasing choices for consumers
- Encourage the substitution of harmful substances
To fulfil the objectives of the SCIP database, information submitted to the database will be made publicly available through the ECHA Dissemination Platform. The Dissemination Platform is still being developed, and we can expect it to be available at the end of summer of 2021.
Up to this point, companies have been rushing to meet the compliance due date of January 5th, 2021. The number of notifications ballooned from 50,000 at the beginning of December 2020 to 2 million in by mid-December 2020. A month later, in January 2021, 5 million notifications have been submitted to the SCIP database! This was more than what ECHA had anticipated.
ECHA sent information in their newsletters on how companies can improve their notifications and remind them the goal of the SCIP database – provide information in an understandable manner for waste operators and consumers regarding SVHCs in articles. In the ECHA SCIP IT User Group meeting on May 27th, 2021, ECHA gave a first glimpse of the Dissemination Platform.
Who can access the SCIP Dissemination Portal?
Everybody! And by that, we mean anybody, really anybody, who wants to look up information. ECHA generally identifies three groups of people:
- Waste Operators, they can use the information to help them sort and recycle products
- Consumers, so that they make informed choices on how articles are best used and disposed
- Authorities, in order for them to monitor the use of SVHCs and support policy decisions
Which of my submitted information will be publicly accessible in the ECHA Dissemination Portal?
According to ECHA, data will be published as it has been received except for information about the duty holder. This means that besides data relating to the submitting legal entity, all the other submitted data that is included in the SCIP database notification can be viewed by anyone who accesses the dissemination portal. This means the following information can be viewed:
- Article name
- Article category
- SVHC details in the article
- Information if the article was produced in the EU
- Safe use instruction for all levels of the product structure
If you wondered if you read correctly: Yes, the complete product structure of complex objects as included in the notification will be publicly accessible. This is an example provided by ECHA at the IT User Group meeting on May 27th, 2021:
Yikes! Can I delete submitted SCIP database notifications?
No. Once a notification has been submitted, you cannot delete it. However, you can update your notifications and resubmit them to the SCIP database.
How can I protect my confidential business information?
It depends on what you understand to be “confidential business information”. For ECHA, this is limited to the disclosure of links between actors in the supply chain and information sources. This means that ECHA will not publish information relating to the submitting legal entity of the notification. Everything else, such as the complete product structure and the names of components therein will be publicly accessible.
Therefore, it would be wise for companies to establish a reliable way of limiting the disclosure of confidential business information to the necessary legal minimum. They need to think about additional measures or changes they wish to make to protect confidential information.
Our solution opesus EHS Product Notification runs on SAP and gives companies complete control of the data they are publishing while ensuring that they comply with the requirements of the SCIP database. You can fill out our contact form to speak to one of our experienced consultants.