In 2015 the European Union adopted an action plan to bring about a more circular economy. The aim of a circular economy is to minimise the use of resource inputs and the creation of waste, moving away from the traditional “take, make and dispose” model of the linear economy 1. In order to achieve this the waste framework directive was created setting out measures to reduce the “adverse impacts of the generation and management of waste on the environment and human health” 2.
In 2018 the revised waste framework directive came into effect, tasking the ECHA with developing a database with information on articles containing Substances of Very High Concern (SVHC). This information will aid waste operators in sorting and recycling articles containing these substances while also keeping customers informed about their products and the best methods to dispose of them.
The SCIP Database
The database that has been established under the waste framework directive is for information on Substances of Concern In articles as such or in complex objects (Products) 3. The directive states that from the 5th of January 2021 all companies that produce, import or supply articles containing any SVHC on the candidate list, in a concentration above 0.1% weight by weight (w/w) will have to submit information on these articles to the SCIP database. The database will be used to complement the existing communication and notification obligations for Candidate List substances in articles under REACH.
A prototype of this database has been launched on the ECHA website, this will enable companies to become familiar with the preparation of SCIP notifications and test out the software prior to its official launch. The prototype contains three different elements in the established IUCLID software format, harmonising the notification process, the three elements include:
- Data preparation in IUCLID.
- Data submission in the ECHA Submission portal.
- Material for system-to-system submission of data
Test submission data can be submitted to the prototype in order to gain hands on experience with the software, this test data will be considered as such and deleted prior to the end of October 2020 4.
Who Needs to Submit a Notification?
The requirement to submit a notification to the SCIP applies to all articles placed on the EU market containing a SVHC in greater than 0.1 % w/w 5. Information regarding the articles need to be provided by the following entities:
- EU producers and assemblers.
- EU importers.
- EU distributors of articles and other actors in the supply chain placing articles on the market.
Retailers and other members of the supply chain are not obliged to provide information to the SCIP database.
How to identify the SVHCs in your articles?
The most direct method to determine the presence of any SVHCs in your articles would be to test for each of these compounds in your article. This could prove to be very expensive for suppliers of multiple articles, the cost of testing one article for all of the SVHC on the current list could range between €500 – €700 which will increase as more substances are added to the current list. There are some alternative methods which have been adopted by many companies worldwide:
- Determining the presence of any SVHCs in your articles can be carried out by collecting hazardous data from other members in your supply chain, this would include the testing reports. Some companies employ the use of various software in order to streamline this process including IMDS, Bomcheck, chemSHERPA and ECBOS® GPM.
- Searching the hazardous material database, which contains data on many hazardous substances, the assessment report will provide you with a risk profile of your allowing you to more accurately determine what SVHCs could be present.
- Carrying out preliminary laboratory screening to rule out any unnecessary testing would therefore lower the cost of testing for the presence of SVHCs in your article.
How CIRS Can Help?
- SVHC testing
- Identify the information required for submission to the SCIP database
- Dossier preparation and notification review
As a world leading Regulatory consulting firm, CIRS cover the global scope of regulatory compliance, providing a one stop service, tailor made to your needs ensuring that you remain compliant with this and all future regulations.
- CIRS can provide SVHC testing at our state-of-the-art testing centre in China by using our own laboratory we can provide a quality testing service at a relatively low cost. For a quotation please contact firstname.lastname@example.org.
- CIRS has dedicated teams across the world who are providing regulatory assistance with hazardous chemical substance to many companies. CIRS maintains the most up to date information on hazardous chemical regulations and provide real time barrier free communication with international manufacturers and suppliers ensuring a quality and robust service.
- CIRS already has extensive experiences with EU REACH completing 2,000 full chemical registrations and 1,000 SVHC notifications up to 11 March 2020.
The Potential Timeline
Preparation is the key to remaining compliant, any manufacturers and suppliers of articles that may have to comply with this new directive can begin now. Firstly, by familiarising themselves with the prototype database that is now available on the ECHA website until the end of October 2020. As the Directive officially comes into effect on the 5th of January 2021, it would be best to begin collecting preliminary data on your articles in the near future depending on the number of articles you manufacture and supply. Once the articles that could potentially contain SVHC have been identified testing to confirm the presence and concentration of those chemicals in the article can be carried out. A conservative timeline for one article can be seen below (testing service provided by CIRS).
(1) Geissdoerfer, M.; Savaget, P.; Bocken, N. M. P.; Hultink, E. J. The Circular Economy – A New Sustainability Paradigm? J. Clean. Prod. 2017, 143, 757–768. https://doi.org/10.1016/j.jclepro.2016.12.048.
(2) Understanding WFD - ECHA https://echa.europa.eu/understanding-wfd.
(3) SCIP Database - ECHA https://echa.europa.eu/scip-database.
(4) SCIP Prototype - ECHA https://echa.europa.eu/scip-prototype.
(5) ECHA. Detailed Information Requirements for the SCIP Database Document Title Detailed Information Requirements for the SCIP Database Contents; Helsinki, 2019.
Mr.Dean Winder, Consultant, CIRS Ireland
Contact: +353 1 477 3710