The January 5, 2021, deadline to submit substances of very high concern (SVHC) data to the Substances of Concern In articles, as such or in complex objects (Products) (SCIP) database is approaching quickly. Is your company ready to meet additional market access scrutiny in the European Union (EU)?

The EU is working toward delivering a more detailed picture of what enforcement will look like in the coming years. Although it’s generally accepted that it will carry penalties such as product recalls, reformulation, and market loss, the EU Waste Framework Directive (WFD), which carries the SCIP submission requirements, does not outline enforcement targets or standards.

Join our webinar, REACHing the SCIP Database Deadline, for up-to-date insight into how to comply with the EU Waste Framework Directive.

Instead, it is largely understood that enforcement actions will be deployed under Regulation 2019/1020/EU on market surveillance and compliance of products. Set to take effect on July 16, 2021, the regulation sets enforcement priorities for all 69 existing EU market access laws under one initiative, ensuring products placed on the market are safe and compliant.

Authorities will centralize enforcement data under yet another new database, the Union Product Compliance Network (UPCN), which also has a go-live date of January 1, 2021. This database will act as a shared hub for all EU Member State Competent Authorities (MSCAs) to submit enforcement reports and regulatory data. This includes systems such as EU Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Authorisations, the SCIP database, and the EU Biocidal Properties Regulation.

Although there is a current system for basic data sharing, the UPCN will be more comprehensive, and enable alerts to member states for any products that lack data and may need further scrutiny.

New Powers for EU Enforcement Authorities

As expected with regard to the EU WFD, the legislation introduces new powers to stop products on import, and make a compliance check to ensure products are safe. The July deadline is a clear signal that regulatory bodies expect companies to complete their SCIP submissions in a timely manner.

Powers granted to authorities through the EU WFD and Regulation 2019/1020/EU on market surveillance and compliance of products include the ability to:

  • Perform random testing on products believed to contain SVHCs or lacking in safe-use data, with testing costs charged back to the company.
  • Share and exchange information with other enforcement authorities.
  • Retrain over 1,000 enforcement officers on how to analyze products consistently under the Ref-9 REACH enforcement initiative.
  • Issue warnings to update packaging and websites with proper labels.
  • Leverage the UPCN to identify issues that trigger testing requirements and further scrutiny.
  • Ban products from the EU.

This centralizes EU enforcement related to SVHCs and shows enforcement efforts will continue to expand.

Assent Manages Your SCIP Submission

The Assent Compliance Platform provides companies with an efficient EU WFD solution, engaging suppliers and managing SVHC data cost-efficiently and accurately. Assent can build SCIP dossiers for your company and sync them to the SCIP database, managing your data from collection to final submission.

To learn more, contact our experts today.

Dr. Raj Takhar
Regulatory & Sustainability Expert, Product Sustainability

Raj helps companies meet their product compliance challenges in an ever-changing regulatory landscape. He specializes in product compliance, chemical reporting, and program implementation in Europe.

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