What is the EU Waste Framework Directive and why does the SCIP database matter for manufacturers?

The EU Waste Framework Directive (WFD) is a cornerstone of the European Union’s circular economy strategy, requiring manufacturers to design products for durability, reuse, and waste reduction. A key update in 2018 introduced the SCIP database, the Substances of Concern In articles as such or in complex objects (Products) database, managed by the European Chemicals Agency (ECHA). Manufacturers, importers, and assemblers must report products containing Substances of Very High Concern (SVHCs) above 0.1% weight-by-weight (w/w) to the SCIP database. This improves supply chain transparency and supports safe recycling and waste handling.

Who must submit data to the SCIP database under the Waste Framework Directive?

Any company that manufactures, assembles, imports, or distributes products in the EU market containing SVHCs above 0.1% (w/w) must make a SCIP submission.EU-based companies, including first importers have direct legal responsibility.Non-EU suppliers must provide data to their EU partners to maintain market access.The only exception is retailers selling directly and exclusively to end consumers. To determine if you’re in scope, review your supply chain data against the REACH Candidate List, which is updated about every six months.

How does SCIP reporting differ from REACH compliance?

While both REACH and SCIP address hazardous substances, SCIP goes deeper.REACH focuses on the registration and restriction of chemicals.SCIP requires a granular declaration of SVHCs at the article level, including details like material category, safe use information, and concentration ranges. In short, REACH manages chemicals, while SCIP manages transparency, ensuring every product component containing an SVHC can be identified and safely handled at the end of its life cycle.

How can manufacturers efficiently meet SCIP database requirements?

Compliance begins with accurate data collection and supplier collaboration. Manufacturers should:Map all products and identify SVHCs.Collect detailed article- and material-level data following ECHA’s IUCLID format.Use a compliance management solution to automate submissions and maintain accuracy.Solutions like Assent’s SCIP compliance software centralize supplier data, track REACH Candidate List updates, and simplify dossier submissions, helping companies shift from reactive compliance to proactive risk management.

What is changing with REACH regulations regarding hexavalent chromium (CrVI)?

The European Chemicals Agency (ECHA) is expected to move multiple CrVI substances (already classified as REACH SVHCs) from the REACH Authorisation List to the REACH Restricted Substances List (Annex XVII). This means that substances like chromium trioxide, chromic acid, and 12 additional CrVI compounds will no longer require prior approval but will instead be banned from use in products and parts in the EU market. A restriction proposal is expected by April 11, 2025.

Why is REACH moving CrVI from authorization to restriction?

The current REACH authorization process has failed to keep up with the high volume of industry requests. Instead of the required three-month review period, CrVI authorization requests have taken an average of 14.5 months, leading to annulled decisions, compliance uncertainty, and supply chain disruptions. An EU ombudsman audit found procedural issues and data quality concerns, prompting calls for a more efficient, transparent process. This led to a full restriction as the preferred solution.

What will the new hexavalent chrome restriction cover?

The expected restriction will likely apply to articles containing CrVI compounds, especially those with components that may come into direct and prolonged contact with the skin. This would expand on the existing restriction under REACH Annex XVII, which currently prohibits leather articles containing CrVI at concentrations of 3 mg/kg (0.0003%) or higher. The new rule could significantly impact industries such as automotive, aerospace, and defense manufacturing.

How can manufacturers prepare for the CrVI REACH restriction?

Manufacturers should take proactive steps to ensure compliance before the restriction is finalized. This includes:Engaging suppliers to identify any CrVI usage in the supply chainExploring alternative materials and coatings to replace CrVI substancesMonitoring ECHA updates to stay ahead of compliance deadlinesImplementing a REACH compliance strategy to prevent costly disruptions