As the January 5, 2021, deadline for submission into the Substances of Concern In articles, as such or in complex objects (Products) (SCIP) database looms closer, the European Chemicals Agency (ECHA) continues to make European Union (EU) Waste Framework Directive (WFD) requirements clearer. One of the most recent updates brought distributors into scope of the SCIP database, and added requirements for them to submit data for products that contain substances of very high concern (SVHCs).
Simplified SCIP Notification
The simplified SCIP notification (SSN) is a process targeting distributors. Applicable only if the article or complex object received is not changed in any way before it is distributed, SSN requires distributors to submit a notification by referring to data submitted by their supplier. Although no dossier is required, the distributor must link to the notification provided by the supplier. This can be done either through a manual extract and import process between a supplier and distributor through the ECHA SCIP submission portal, or can be automated using a system-to-system connection.
Learn if you’re in scope of EU Waste Framework Directive requirements with our EU Waste Framework Directive Scoping Guide.
Effect of SSN on Distributors
In the past, it was not unusual for distributors to be exempt from many regulations as long as they did not make any changes to the products they were handling. ECHA’s duty holder obligation for distributors brings them into scope of the SCIP database, and introduces requirements that companies must comply with in order to maintain market access and avoid fines.
To maintain compliance with the EU WFD, distributors will need additional processes in place to submit SCIP articles under the appropriate legal entities and provide a receipt indicating new SCIP numbers. Assent not only provides the support and regulatory expertise to help you keep up with these requirements, but has assembled a number of free resources you can use to get up to speed.