SCIP Database Deadline Upheld by the European Commission & ECHA

SCIP Database Deadline Upheld by the European Commission & ECHA

The European Commission and European Chemicals Agency (ECHA) have confirmed that the January 5, 2021, submission deadline for the Substances of Concern In articles, as such or in complex objects (Products) (SCIP) database will remain in place. This comes in spite of requests from an industry group to delay the EU Waste Framework Directive (WFD) requirement by 12 months.

On October 1, 2020, Chemical Watch reported on the commission’s response to the delay request, stating that “the Commission said the 5 January deadline to begin submitting information still stands.”

The delay request had urged European Commission president Ursula von der Leyen to take “urgent political action” that included a one-year delay for the submission requirements. It also asked the European Commission to reevaluate the efficiency of the SCIP database, including its “usefulness, feasibility, proportionality, and impact.”

Learn more about your new EU market access requirements in our eBook, Understanding the EU Waste Framework Directive & SCIP Database Reporting.

European Commission & ECHA Stand Firm on EU Waste Framework Directive Requirements

The European Commission’s response indicated that industry has had sufficient forewarning of their requirements, and that the deadline has been set since May 30,

2018. It also said that member states and stakeholders have been “extensively consulted throughout the process.”

The industry association’s letter was challenged by the European Environmental Bureau and ClientEarth, whose own letter to von der Leyen asked her “not to cede to industry demands,” and that it would be “undemocratic and illegal for the commission to defer the entry into force of an obligation that the co-legislators set with a specific deadline, or to weaken the obligations they created in any way.”

This position was supported by over 49 other non-governmental organizations (NGOs). This indicates that failure to meet SCIP database submission requirements could lead to additional reputational damage for non-compliant companies.

This could affect a lot of companies. On November 6, 2019, ECHA published results of an enforcement pilot conducted between October 2017 and December 2018. The findings revealed that 12 percent of the articles inspected contained Candidate List substances above the 0.1 percent weight over weight (w/w) threshold, and 88 percent of those failed to submit the right data to customers.

Preparing for the SCIP Deadline With Assent

Assent is helping the world’s largest enterprises manage EU WFD data and meet their SCIP database requirements. We provide the regulatory expertise to help you keep pace with evolving product compliance standards, the support to manage your program should you need it, and the technical guidance to produce SCIP dossiers that meet the scrutiny of enforcement.

To learn more, contact our experts at

Tagged with