In a position paper, the European umbrella organization of engineering industries, ORGALIM (Organisme de Liaison des Industries Métalliques Européennes), requests a one-year postponement of the deadline for the reporting requirements related to articles containing SVHC to January 2021. The association represents the interests of about 770,000 companies in mechanical engineering, electrotechnology, electronics, and metals technology that produce a third of all European exports. ORGALIM questions the benefits and feasibility of the deadline.
Article 9, Section 1, Letter i of the updated EU Waste Directive (Directive 2018/851) is the background of the reporting requirement. The article obligates companies to report on SVHC in articles marketed from January 5, 2021 onward if the articles contain chemicals on the candidate list in a quantity greater than 0.1% weight by weight (w/w).
The goal of the reporting requirements is to uncover the presence of SVHC in articles and eliminate them from material cycle step by step. However, ORGALIM states that the operators of waste processing facilities doubt the usefulness of such a database. That’s why the association requests an impact assessment as the most-pressing measure needed to clarify the added value before burdening companies with added costs. Because of the economic effects of the Corona crisis, the reporting requirements hit small and midsize companies especially hard. In fact, the products produced by such companies are usually quite complex, and the greater the complexity, the greater the effort and cost associated with reporting. The position paper uses a manufacturer of valves as an example. A value consists of three individual products. The manufacturer would be required to create 12,800 notifications each year.
In many cases, information is not available in the supply chain and must be captured before any reporting – which is hardly possible in the short time remaining. This issue raises another criticism for ORGALIM, which decries the scope of the information required. It feels that the requirements far exceed those stated in Article 33, Section 1 of REACH, which is the basis for the EU Waste Directive.
ORGALIM offers three solutions that would be most effective:
1. To concentrate on SVHC that pollute waste the most and therefore create problems for recycling. Otherwise, a danger exists that companies would become bogged down in the details of millions of articles and more than 200 hazardous chemicals.
2. To concentrate on a mass-based approach. The environment benefits more from the improved recycling of 10 articles that contain 10% SVHC than from recycling 1,000 articles that contain 0.1% SVHC.
3. To take precautions and replace SVHC from the start. In this approach, manufacturers would have to contribute their share along with research institutes and waste processors – at best in the context of EU
programs that support innovation.
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