Complying with notifications for substances of very high concern
In July 2018, a revised Waste Framework Directive (WFD) entered into force that introduced the 'Substances of Concern In articles, as such or in complex objects (Products) (SCIP) database'. This database is a result of ECHA's overarching aim to move towards a more circular economy by providing waste operators with information to improve their handling of hazardous chemicals at the end of their life cycle.
From 5 January 2021, ECHA will require companies to submit information for inclusion in the SCIP database on any substance of very high concern (SVHC) that will be used in articles/complex products that an organisation places on the European Union (EU) market. This poses a new challenge for organisations because they must now become familiar with the complex nature of their products before the deadline.
These articles can be produced in the EU or imported from non-EU countries. While this new legislation comes from the European Commission, it will be the duty of individual Member States to transfer this Directive into their own national law by July 2020. As a result, enforcement of this law may differ depending on the Member State in which your company submits its notifications.
What is the SCIP database requirement?
Any article containing an SVHC that is on the REACH Regulation Candidate List, with a concentration of 0.1% weight by weight (w/w) or above will need to be notified to ECHA via the database. This should be completed within 6 months of the SVHC being includedon the Candidate List. The requirement also includes all complex objects where the product is made from more than one article. Companies that produce, import or supply articles containing substances on the Candidate List will have to submit information on these articles to the SCIP database.
Substances on the Candidate List are subject to assessment and review to establish appropriate future action. This action may include inclusion onto the ECHA ‘Authorisation List’ and restrictions to use. New substances are also regularly being added to the Candidate List.
What should be submitted to the SCIP database?
Companies must submit the following information:
- Substance identifiers.
- Name, concentration and location of the SVHC in the article/product.
- Safe-use information for the articles.
- Waste management advice according to ECHA .
Information submitted will be made available to consumers and waste operators to provide greater clarity throughout a product's whole lifecycle. Organisations must now ensure they keep up to date with their obligations under REACH and the WFD.
The official information requirements set out by ECHA will not change before the 2021 deadline. Companies are encouraged to begin preparing their submissions now as the database is planned to be launched by the end of October 2020 and will be open to receive data to fulfil legal obligations.
SCIP notification process
The SCIP notification process consists of three main steps:
- Dossier preparation – using IUCLID cloud, offline via IUCLID 6 (server and desktop) or via system-to-system submission.
- Dossier submission – through ECHA’s submission portal.
- Submission report.
SCIP database prototype
In February 2020, ECHA released the first prototype of the SCIP database.
The SCIP prototype enables relevant duty holders to familiarise themselves with the format and submission tools developed by ECHA before the official database is launched. Companies can practise preparing a SCIP dossier and the process involved in the notification to the database.
All data submitted to the prototype will be deleted as ‘test’ data before the official process begins. Users are also encouraged to provide feedback as improvements and updates will continue to be made before the deadline.
What are the benefits of using NCEC’s SCIP notification services?
- Tailored support and guidance for product notifications – NCEC maintains an extensive database in conjunction with the ECHA lists – which holds the SVHCs on the Candidate List. 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 in 2021.
- Reduced time, expense and resource investment required to understand the complex nature of your products and the submission requirements of the database. Our expert team will be on-hand to help you through all the steps of the notification process.
- Expert advice – our regulatory experts sit on the ECHA working groups and have been active in the guidance provided by ECHA on a variety of legislation. We can help you make informed and up-to-date decisions to enable compliance with the ever-changing regulatory landscape. Our in-depth knowledge of the global supply chain means we are ideally placed to assist you in understanding your obligations and prepare for any future changes.
- Bespoke service – our services can be tailored to your specific needs. We can also provide consultancy support to help you undertake your own notifications.
Choosing NCEC to undertake a fully outsourced or support service means you’ll benefit from our experience, and reduce your notification time and cost enabling your compliance with regulatory legislations.
If you require any further assistance regarding the SCIP database, how to make notifications to this database or want to find out how NCEC can help you, please do not hesitate to contact us using the form on the side or email us at [email protected].
Image source: European Chemicals Agency (ECHA)