The revised European Union (EU) Waste Framework Directive (WFD) mandated the creation of a new database of articles and products containing Substances of Very High Concern (SVHCs) above the 0.1 percent weight by weight (w/w) threshold. Companies doing business in the EU, from manufacturers to importers to distributors, will be required to submit new information to the Substances of Concern In articles, as such or in complex objects (Products) (SCIP) database no later than January 5, 2021. The deadline is now less than a year away, however, there are other important dates that companies should be aware of as they relate to managing SCIP database requirements.
Testing
On May 30, 2018, the EU WFD assigned the responsibility of creating and managing the database to the European Chemicals Agency (ECHA). January 5, 2020, was the original target for company submissions, however, that was not met. This year will see the ECHA roll out several key aspects of the database, and they are widely expected to release a preliminary database testing environment in February.
More testing will be done in June and July of 2020, as the database is expected to be made available to IT solution providers to explore system-to-system communications. A launch window for machine-to-machine submission is expected in the last quarter of 2020.
Enforcement
Member states will establish enforcement of SCIP data requirements as mandated in the EU WFD. The deadline to transpose EU WFD requirements into national law is July 5, 2020. Member states will explain penalties for non-compliance, possible exemptions and other relevant information. While legislation may differ, all member states must list January 5, 2021, as the start date for compliance.
The EU WFD, as a waste directive, may see enforcement guidelines similar to another waste law: the Restriction of Hazardous Substances (RoHS) Directive. EU Directive 2019/1020 established common criteria for member state enforcement authorities to assess and exchange data on products entering the market. The directive may result in more severe fines and penalties for companies.
Whether you’re just beginning your SCIP process or gearing up for the final submission, the SCIP Registration Center has resources and free tools to ensure you’re successful. Visit it today.
Data Submissions
Information about SCIP database requirements is available, and efforts to scope the supply chain should begin immediately. Companies should begin creating SCIP-acceptable dossiers to avoid missing the deadline. Companies may submit their data in one of three ways:
- Online through the ECHA submission portal.
- Preparing documents offline with an IUCLID 6 SCIP specific interface.
- Through a system-to-system integration.
Each submission must meet ECHA-established criteria in order to be accepted.
How Assent Can Help
Assent offers a comprehensive solution to your SCIP database obligations. The Assent Compliance Platform is able to integrate with your current programs to efficiently scope your supply chain against SCIP requirements, and manage your submission from data acquisition to final upload. To learn more, contact us today.
