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CONSUMER PRODUCTS AND RETAIL E-SSENTIALS

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EU: ECHA Officially Launched the SCIP Database

DECEMBER 2020 - ELECTRICAL AND ELECTRONICS, HARDLINES, SOFTLINES, TOYS AND CHILDREN'S PRODUCTS

Back in 2018, the European Commission amended the Waste Framework Directive through Directive (EU) 2018/8511, which introduced a new notification obligation related to Substances of Very High Concern (SVHCs) in articles in parallel to the existing communication obligation under the REACH Regulation. The new obligation will close the information gap for the waste sector to be able to access the same information available in supply chains, enabling them to improve the current waste management practices and to foster the use of waste as a resource.

Starting from 5 January 2021, suppliers of articles on the EU market will be required to notify the European Chemicals Agency (ECHA) if their articles contain SVHCs above 0.1% by weight (w/w). The ECHA is tasked with creating and maintaining the SCIP database (Substances of Concern In articles as such or in complex objects (Products)) for this purpose. A prototype of the SCIP database was available in February 2020 and after months of discussions with stakeholders, the final version was officially launched2 on 28 October 2020. SCIP notifications can now be submitted to allow the suppliers sufficient time to be compliant for the January deadline. Information in the database will be made available to waste operators and consumers from February 2021.

The minimum information which a supplier needs to submit in a SCIP notification consists of the following:

  1. information that allows the identification of the article;
  2. the identification of the Candidate List substance in the article, its concentration range and its location, as appropriate; and
  3. possibly any other information on the safe use of the article, available to the supplier, notably information which is necessary to ensure proper management of the article once it becomes waste.

A supplier who has the responsibility to submit SCIP notifications is called a duty holder.  A duty holder is a natural person or a legal entity in the EU who supplies articles on the EU market, including:

  • producers and assemblers;
  • importers;
  • distributors of articles and other actors who place articles on the market.

Retailers who are not simultaneously importers and/or producers, and other supply chain actors supplying articles directly and exclusively to consumers are not covered by the obligation.

While non-EU persons or legal entities have no direct obligations to fulfil this new requirement, they can submit SCIP notifications directly on behalf of a duty holder in the EU who has appointed them as a foreign user for this obligation.

As the SCIP notification obligation is triggered by the same criteria as for the REACH communication (Article 33(1)) obligation, potential duty holders should consider updating their current SVHC compliance programs by understanding their SCIP notification obligation, carrying out an impact assessment on their product portfolio, reviewing and updating their compliance policy where necessary, and most importantly, communicating with and managing their supply chain.

[1]  Directive (EU) 2018/851 – Amendment to Waste Framework Directive

[2]  ECHA press release – Official launched the SCIP Database

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