SCIP Database: Small and Medium-Sized Enterprises (SMEs) Call for an Alternative Solution

The SMEunited trade association supports the European Commission’s plan to abolish the SCIP database – the central EU-wide register for substances of very high concern (SVHCs) in products – and, consequently, the reporting requirement. It argues that the requirement places an undue burden on small businesses and offers only limited benefits.

Instead, in a position paper, SMEunited calls for waste disposal and recycling companies to have access to clear and actionable information. It states that only this approach can ensure safer recycling and efficient material recovery. The paper argues that the current SCIP system is excessively complex, costly, and associated with a high administrative burden.

The alternative

As an alternative, the trade association advocates for the Digital Product Passport (DPP). It views the DPP as a long-term solution for tracking hazardous substances in products. However, SMEs require sufficient time to adapt their processes and prepare for the new requirements in a structured and cost-effective manner. The DPP is being phased in across the EU in accordance with the Ecodesign for Sustainable Products Regulation (Regulation 2024/1781; ESPR). The first mandatory requirements for prioritized product groups should take effect starting in 2027. Plans call for a gradual expansion to other sectors through approximately 2030.

The original plan

With the EU Waste Framework Directive (Directive 2008/98/EC), as amended by Directive (EU) 2018/851, and the SCIP database, the EU aimed at making hazardous substances in products identifiable, thereby supporting recycling facilities and promoting the circular economy. Accordingly, since January 5, 2021, the affected companies have been required to report information on articles to ECHA if they contain SVHCs in a concentration exceeding 0.1% by weight. However, since then, criticism from non-governmental organizations and industry associations, including the European Recycling Industries Council (EuRIC), has been constant. The ECHA also stated that it has only minimal resources available for maintaining the SCIP database.

The EU’s concession

The EU has responded and aims to reduce bureaucracy and strengthen the EU’s competitiveness through the omnibus packages. In fact, the draft of the Environment Omnibus Package published on December 10, 2025 provides for the abolition of the database. According to EU estimates, this move could save companies around €225 million annually. And the resulting impact on health and the environment would be negligible.

Next steps

The public consultation on the Environmental Omnibus Package accepted comments until May 7. After evaluating the feedback, the European Commission will revise the draft. The Commission will then submit the final proposal to the European Parliament and the Council of the European Union for deliberation and decision-making. The final legislative text will then be negotiated and adopted during tripartite negotiations. Publication in the Official Journal of the EU is not expected before 2027.

If you have any questions about the Chemicals Omnibus VI package, please contact us at any time at sales@kft.de.