The European Union (EU) Waste Framework Directive (WFD) was revised in 2018, introducing mandatory requirements for a centralized database of Substances of Very High Concern (SVHCs) in articles and products to be managed by the European Chemicals Agency (ECHA). This database, the Substances of Concern In articles, as such or in complex objects (Products) (SCIP) database, is intended to make SVHC information available throughout the whole lifecycle of articles and materials. Duty holders must submit this information by January 5, 2021.
With less than a year to go until the deadline, manufacturers with SCIP database reporting obligations are working to collect appropriate data to ensure they submit all the right information to the finished database.
Key Information to Communicate to the ECHA
Article 33(1) of the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation requires suppliers of articles to communicate the presence of SVHCs above a 0.1 percent weight by weight concentration to other actors in their supply chain. Beyond this basic information, the ECHA has outlined three primary data sets suppliers of articles must submit to ensure compliance with the EU WFD:
- Information that allows for the correct identification of an article.
- The name, concentration and location of the SVHCs in the article.
- Information on the safe use of an article, especially as it pertains to waste management.
Gathering this data requires duty holders to work closely with actors in their supply chains to prepare article data sets. These data sets contain information on finished articles (typically an individual article that contains an SVHC) or a complex object (consisting of multiple lower-level articles that may contain SVHCs) [Figure 1]. Article data sets are then used to develop dossiers. Each article record generated with the accompanying required information can be submitted as individual dossiers or as a single dossier for a complex object [Figure 2].
Because of the breadth of this information, the ECHA has provided a detailed list of mandatory and optional data fields for duty holders to gather for a SCIP dossier submission.
For more information on data requirements for duty holders, download our eBook, Understanding The EU Waste Framework Directive & SCIP Database Reporting.
Fig. 1: Article datasets vs. dossiers. [European Chemicals Agency. (February 2020). SCIP Database Notifications: How to prepare and submit a SCIP notification dossier. Retrieved from https://echa.europa.eu/documents/10162/28213971/SCIP_Database_Notifications.pdf/63a1dbe6-20ce-2e37-46be-4293c809dc2f]
Fig. 2: SCIP Dossiers [European Chemicals Agency. (February 2020). SCIP Database Notifications: How to prepare and submit a SCIP notification dossier. Retrieved from https://echa.europa.eu/documents/10162/28213971/SCIP_Database_Notifications.pdf/63a1dbe6-20ce-2e37-46be-4293c809dc2f]
Article identification requirements constitute the majority of data requirements under the SCIP database due to the European Court of Justice ruling known as “Once an Article, Always an Article.” Mandatory article identification requirements include:
- The name of the article.
- A primary article identifier.
- A numeric or alphanumeric identifier assigned to the article to support the preparation of a notification to the SCIP database (it’s recommended that companies use the ECHA article ID as a universally unique type record to identify the reported article). Additional primary article identifier values can also be submitted to provide further information.
- The article’s category.
- This should identify the article from a harmonized list based on function or use.
- Production in the EU.
- Companies must identify whether the article was produced or assembled in the EU. This field will only be used for statistical data by the European Commission when further assessing the use of SVHCs in articles.
Optional requirements include:
- Other article name types and values.
- Allows for attributes such as brand, model or type to be used to identify an article. As with primary identifiers and names, additional values may be submitted to provide further information.
- Other article identifier types and values.
- This allows companies to repeatedly use the Primary Article Identifier type fields to provide additional information. For example, because consumer products have specific requirements to report data in either the primary or optional article identifier field, an identifier such as the European Article Number (EAN) should be provided in this field.
- Characteristics types and values.
- Additional characteristics of the article, including pictures, dimensions, density, weight, volume, color and more.
Information on the SVHC(s) included in the article must also be submitted to the SCIP database. This includes a variety of mandatory and optional data types. Mandatory requirements include:
- The version of the Candidate List used to identify the SVHC.
- The Candidate List substance identified in the article, using Chemical Abstract Service (CAS) and/or European Community (EC) numbers.
- The concentration range of the substance in the article.
- Identification of one of the following fields to determine how the SVHC arrived in an article:
- A Material form based on an ECHA harmonized list.
- A Mixture form based on the European Product Categorisation Systems (EuPCS).
Manufacturers may also optionally submit additional material characteristics. In situations where an SVHC is no longer present in an article, manufacturers may also submit this information.
Safe Use Information
Safe use information, particularly information that is necessary to ensure proper management of an article once it becomes waste, is another mandatory component of a SCIP database submission. Manufacturers must provide this information in sufficient detail to enable proper risk management, and are responsible for checking whether the ECHA’s Information on Chemicals resource identifies known hazard labels, hazard statements and safe use information relating to an SVHC.
Upon viewing the ECHA’s Information on Chemicals resource for a given SVHC, duty holders are expected to identify if any additional safe use statement is required. Duty holders have access to a flag that states that there is “no need to provide safe use information beyond the identification of the Candidate List substance.” If the ECHA’s Information on Chemicals resource provides no safe use information for an SVHC, article manufacturers should refer to Safety Data Sheet information provided by the material/mixture manufacturer, if available.
Gathering data to meet SCIP database requirements is a challenging, detail-oriented process that requires significant supply chain engagement. Manufacturers facing the looming SCIP database submission deadline may find it to be a daunting process. However, by leveraging third-party software such as the Assent Compliance Platform, these companies can leverage automation to acquire the data they need to generate a complete SCIP database submission.
To learn how Assent can support your company, contact us.