How to Time Your SCIP Database Compliance for the Waste Framework Directive

How to Time Your SCIP Database Compliance for the Waste Framework Directive

The European Chemicals Agency (ECHA) has released preliminary details on the upcoming substances database mandated under the European Union (EU) Waste Framework Directive (WFD). The purpose of the database — known as the Substances of Concern In articles, as such or in complex Products (SCIP) — is to promote a safe, circular economy by increasing  product composition transparency for waste operators and consumers. As such, information submitted to the database will be publicly available. For details on the announcement, see our article, The ECHA Announces SCIP Database for Improved Transparency on Hazardous Substances in Articles.

Where to Focus Attention

To collect, organize and report the required data by the deadline on January 5, 2021, companies must take immediate action. However, many organizations are unsure how to proceed with their SCIP compliance because stakeholders are still advocating for change to the legislation and member states have significant time to implement local acts, which could lead to amendments.

You should plan for the following steps:

The Political Context

Recent parliamentary elections in May 2019 provide insight into how upcoming legislation, including submission requirements for the SCIP, will be shaped. A significant increase in parliamentary members affiliated with a green party suggests more attention will be given to environmental issues. This includes a greater push for restrictions on toxic chemical use in favor of non-hazardous alternatives.

The EU has already committed to increasing regulatory enforcement in 2019, so businesses should expect requirements related to the SCIP to be closely monitored and enforced. Additionally, because submitted data will be publicly available, companies should prepare for increased pressure from non-governmental organizations (NGOs) and other activist groups.

Given these factors, companies should expect more stringent regulatory requirements, especially for those manufacturing products outside of the EU as they will now be expected to provide SVHC data down to the article-level to support their European importers/sellers.

Possible Amendments 

Some companies and industry representatives are formally objecting to the ECHA’s proposed submission fields with many opposing the requirement for non-EU companies to provide information to the article-level, which will substantially increase reporting time, and the fact that information will be made public.

Regardless of whether the ECHA amends these requirements before the deadline, businesses should continue to prepare based on the available information.

Key Dates to Watch for More Information

October 1, 2019The ECHA will present initial database screenshots to REACH-IT members.
February 2020Expected release for preliminary ECHA test database.
June or July 2020Expected time-frame for test database to be available to connect to and provide data.
July 2020All member states are expected to have implemented all applicable local delegated acts regarding EU WFD.
January 5, 2021Full SCIP system will go live.

It is important to note these dates are subject to change due to numerous factors.

Assent participates in committees, attends stakeholder events, and represents multiple industries in trade association events related to EU WFD and the SCIP. For the latest information on database requirements, visit Assent’s blog, and for details on how Assent can help you collect necessary supply chain data, contact info@assentcompliance.com.

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