▪︎ REACH
ECHA SCIP Database: EU Considers Abolition – Consultation Unleashes a Flood of Comments
To promote competitiveness, the EU wants to streamline and reduce the bureaucracy involved with various laws, including chemical regulations. This initiative could also result in the discontinuation of the SCIP (“Substances of Concern In Products”) database. The consultation that ended on September 10 sparked controversial reactions.
At the end of July, the EU launched a consultation and requested feedback on its proposal to abolish the SCIP database and reduce requirements under Extended Producer Responsibility (EPR). The result was a flood of nearly 120,000 comments. Although most industries welcome the proposal, NGOs warn against it.
Criticism of SCIP
- Primarily small and medium-sized enterprises complain about the high costs involved. SCIP obligations would also overlap with other reporting obligations, such as REACH.
- Implementation is difficult for complex articles and products with many components, as well as for end-of-life products, because information is missing.
- The overall cost–benefit ratio is poor.
The original idea
The EU introduced the SCIP database in 2021 and has operated it ever since. The original impetus is closely linked to the objectives of the Waste Framework Directive. According to Article 9 of the EU Waste Directive, manufacturers and importers are required to use SCIP to notify the ECHA about the presence in a concentration greater than 0.1 percent by weight of SVHCs in products. The database provides information about hazardous substances in products. Substance information is collected centrally and made available to authorities and waste management companies.
Differences between REACH Article 33 and SCIP
According to REACH Article 33, suppliers of articles must inform their industrial customers when an article contains a SVHC – as part of the REACH candidate list – in a concentration of more than 0.1 percent by weight.
This information must also be sent to the SCIP database. However, the SCIP requirements go even further. They require structured, standardized data sets, that include, for example, identification of the article, the SVHCs contained, concentration ranges, article numbers, and use information. The addressees of REACH Article 33 and SCIP also differ: REACH is aimed at customers and consumers, the SCIP reporting obligation primarily serves the waste and recycling industry.
The EU Commission will now evaluate the feedback and present its environmental omnibus package by the end of the year.