ECHA Substance in Articles Database Safe Use Proposal Updates Released

ECHA Substance in Articles Database Safe Use Proposal Updates Released

In 2008, the European Chemicals Agency (ECHA) placed the European Union (EU) Waste Framework Directive (WFD) into effect, presenting concepts, provisions and definitions surrounding waste management.

The initial release explains basic guidelines for managing waste and the difference between waste and by-products. Both the ECHA and the WFD support the EU Registration, Evaluation, Authorisation and Restriction of Chemical (REACH) Regulation to remove harmful substances from the European Economic Area (EEA) and encourage more sustainable manufacturing and production practices.

The 2018 revision introduced a new database which companies will be required to report into beginning January 5, 2021. The ECHA’s Substances in Articles (SiA) database was introduced in Article 9(2) of the EU WFD (EU 2018/851) revision in 2018. This directive is meant to support more sustainable waste recycling activities in the EU, and will require manufacturers and importers into the EEA whose products contain a Substance of Very High Concern (SVHC) to submit data into this new ECHA SiA database.

Until now, industry practice has been to provide the name of the SVHC against a product when it exceeds 0.1 percent weight by weight (w/w) threshold level. However, reporting requirements for the SiA database also include:

  • The SVHC and its European Community (EC) and Chemical Abstracts Service (CAS) number where applicable
  • Technical information related to the substance, article entity and their association
  • Administration information related to article entity, party and their association.

Companies will be able to provide data at a substance group level or as an optional substance pertaining to a substance group entry on the ECHA Candidate List of substances.

The current design of the database allows it to operate with minimal content but optional fields may become mandatory as information is uploaded. For example, the database will optionally collect Concentration Levels and Safe Use Information, however Safe Use Information would be mandatory if the substance does not already have defined safe use guidelines in the Candidate List of SVHCs.

When the scope of information required was released, a number of industry groups and trade associations raised the concern that the ECHA’s interpretation of EU REACH Article 33 was too extensive. The concern centered around the requirement for manufacturers to provide “enough information” to allow the safe use of an article by professional users and distributors who receive it, and the requirement to answer requests for information by consumers within 45 days of the request being made.


Learn more about REACH and how it is evolving in our guide, REACH in 2020 & Beyond.


The European Chemicals Agency has been tasked with deploying a version of the SiA database by January 5, 2020 to allow for a year of testing. Anyone manufacturing or placing products into the EEA may optionally report SVHC information during this time. After January 5, 2021, it will be mandatory for anyone manufacturing or placing products into the EEA to report SVHC information into the database.

Once the SiA database is rolled out, waste operators, supply chain actors, duty holders, non-government organizations (NGOs), authorities and consumers will have access to submitted data, however consumers will have a limited view. This transparency is part of a plan to drive a more circular economy in the EEA and encourage companies to design products using sustainable natural resources as a response to a study released by European Commission which concluded that:

Sixteen tons of materials are consumed per person, per year within the EU.

  • Six tons of materials end up as waste.
  • Only 40 percent of this waste is reused.
  • In some countries, up to 80 percent of waste ends up in landfill.

The SiA database initiative encourages recycling waste back into raw materials and enables European companies to avoid the increasing uncertainty and cost of using diminishing natural resources while supporting a reduction of waste which ends up in landfill sites.

Companies’ product data will continue to face new requirements as the global product compliance landscape shifts. Those leveraging a strong supply chain data management solution will be better positioned to maintain compliance by tracking substances that may be subject to future regulations.

To learn how the Assent Product Compliance Suite can streamline your supply chain data collection and reporting processes, email info@assentcompliance.com.

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