REACH Waste Framework Directive - SCIP Database
Reminder : have a look on the previous CEIR newsletter and all explanations on SCIP database. Short summary :
Companies supplying articles containing substances of very high concern (SVHCs) on the Candidate List in a concentration above 0.1% weight by weight (w/w) on the EU market have to submit information on these articles to ECHA, as from 5 January 2021. The SCIP database ensures that the information on articles containing Candidate List substances is available throughout the whole lifecycle of products and materials, including at the waste stage. The information in the database is then made available to waste operators and consumers.
SCIP database entered in force last 5th, of January 2021 … despite all efforts and explanations from the Industry asking the European Commission to take time in order to do together something more efficient and proportional with respect to the actual final use of that big amount of data. Letters from tens of European Associations (including CEIR) to the President of the European Commission, to the Director General of DG ENVI, to German Presidency of the Council with copy to the Presidents of the EU Parliament and the European Council and copy to the relevant attachés in the Brussels Permanent Representations of the Member States did not get consideration and success.
CEIR was not against the basic purpose of SCIP but defends the Industry for proportionality, just necessary, just legal and finally useful requirements.
But the contributing voice of the Industry has not been listened too … it is a pity and not a positive statement of fact and signal for the next dialogs on regulations.
What do you need to do since 5th, of January 2021 … just apply !
For each product you put on the market and containing a so called SVHC (Substance of Very High Concern) listed in the candidate list of substances of REACH and with a concentration above 0.1% weight by weight (w/w), you must notify the reference of that product with many additional information in the database. For example, a lot of materials contains lead with more than 0.1% and products using these materials are subject to notification.
We will not describe here how the notification process runs; there are many possibilities to notify depending on your product characteristics. It is not a simple and easy process. You can notify directly in SCIP or use system to system software tool between our internal data management system and SCIP … but you have to develop or buy that tool. You can find a lot of solutions’ suppliers or subcontractors on the market; that’s a great opportunity for them. As a global overview:
Since 5th, of January, if you do not notify, you are not respecting the law … and you are subject to penalties !
But which law? Like too often, the national transposition of that new requirement is not the same in all European countries … not at all … there is again no “harmonized Europe” with countries having transposed and others not (may be a question of time) but especially countries mentioning the database and others not mentioning it and keeping only mandatory the existing REACH obligation of communication by the manufacturer (the only legal one) … good chance and good (hard) work to fulfill your new obligations !
Building & Industrial Valves TC Chair