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 platform.
It’s been slightly more than a year since the UK left the EU on 31st January 2020. The 11-month transition period ended on 31st December 2020. What does this mean for companies moving their goods between the EU and the UK? This article explores Brexit and the SCIP Database.
In the context of the revised Waste Framework Directive (WFD), the European Chemical Agency (ECHA) was tasked to create a database of substances of concern in articles as such or in complex objects or products (SCIP database). The SCIP database was established to improve transparency on hazardous substances in articles.
In Switzerland, the ordinance on protection against dangerous substances and preparations (ChemO) regulates the placing of substances and preparations on the market. The ChemO is largely similar to the European REACH and CLP regulations except when it comes to the part of registering substances.
The SCIP database requirements pose a challenge not just to companies in the EU, but also non-EU companies whose customers are in the EU. Companies not located in the EU are faced with requirements from EU customers as they face new regulations related to increased environmental pressure, such as the Waste Framework Directive. Hence, non-EU companies should understand the goals of the SCIP database and comply with its obligations.
Twice a year, the Candidate List of substances of very high concern (SVHC) is updated. The most recent update occurred on 19 January 2021. This brings the number of SVHCs to 211. However, when these unique substances are further broken down, the actual number of reportable substances including their substance groups is closer to 400.
The recent ECHA newsletter described ways on how companies can reduce their workload in relation to creating notifications to the SCIP database through supply chain communication. With the deadline for SCIP notifications coming up, being able to rely on supply chain communication to make use of simplified SCIP notifications or using referencing may be a desirable option for many companies.
The SCIP database is developed under the Waste Framework Directive (WFD) to take a step towards a circular economy. With the SCIP database, the product lifecycle is completed with information on substances of concern in articles. One of the things that are a hot topic of discussion is the dissemination of information and protecting confidential business information (CBI).
From 5th January 2021, companies affected by the Waste Framework Directive (WFD) have to submit notifications to the SCIP Database. Affected companies have had the opportunity to test the SCIP database since the SCIP prototype became available in February 2020. Since the launch of the SCIP database in October 2020, ECHA has received two million notifications! This indicates that many companies are at the forefront of managing their SCIP database requirements. Nevertheless, there are many more evaluating the best way to include this new requirement into their business processes. The move towards a more circular economy is being pushed on the European Union level. However, as it is a directive, the next question to ask would be: Has this EU directive been incorporated into national law by all member states?
If you’re placing mixtures on the market only for industrial use, limited submission to the poison centre notification sounds very appealing. You fulfil your notification obligation while providing only minimal data about your mixture. Sounds like a win, right?
Well, take a closer look.