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On 25 October, the European Chemicals Agency (ECHA) announced that the Waste Framework Directive amendment is being extended to the European Economic Agreement. This means that Iceland, Liechtenstein and Norway will now also be required to notify under the SCIP database.
All articles and products to be placed on the EU market that contain a substance of very high concern (SVHC) that is on the EU REACH Regulation Candidate List at a concentration above 0.1% (weight by weight) must be notified to the SCIP database. Products in scope are required to be notified to the public database under the Waste Framework Directive, and ECHA has confirmed that it will be able to receive notifications from these countries from 7 November.
Our regulatory experts have outlined below the likely scenarios where organisations will need to take action.
- Products containing SVHC’s which are sold in an EEA region (Iceland, Liechtenstein and Norway) but not the EU27 – these will now be in scope of SCIP and therefore businesses will need to submit a full SCIP notification.
- Products previously SCIP notified but are also sold in an EEA region (Iceland, Liechtenstein and Norway) – the national importer/distributor will be required to submit a simplified downstream user SCIP notification, in effect extending the initial notification.
- Products manufactured or first imported into the European market through an EEA region – for new products these will require a full SCIP notification. If they have previously had a full initial SCIP notification submitted through a downstream EU27 member, these will need to be processed on a case-by-case basis.
- Products which are sold in the EU27 but not extended EEA regions, which have previously been SCIP notified – no action required.
- Products which do not contain any SVHC’s (or below 0.1wt% in all components) – no action required.
How can Ricardo help?
The SCIP database is proving to be an unpredictable and complex legal requirement. Substances currently on the Candidate List are subject to assessment and review to establish appropriate future action, which may include inclusion on the ECHA ‘Authorisation List’ followed by use restrictions.
Ricardo's horizon scanning and compliance reporting tool can identify whether your substances appear on any relevant regulatory lists, including but not limited to the five REACH Lists, and provide the results in a clear, easy-to-read report. This includes identifying products for which a SCIP database notification is required.
We have an extensive and regularly updated database that is used to monitor the status of your product portfolio, providing you with the most recent developments regarding your substances and enabling your company to become fully compliant. A check against our database can help you better understand the composition of your products and enable you to be ready to submit your notifications.
