Since 5 January 2021, the ECHA (European Chemicals Agency) says there is an obligation to submit data on substances of very high concern (SVHCs) in articles in accordance with the Waste Framework Directive. The new requirements will affect all companies placing articles containing substances of very high concern from the candidate list on the EU market.
The ECHA also reports that companies have already submitted more than five million notifications for inclusion in the database. In the coming months, the ECHA will start publishing the data on its website, and this feature will be further developed. The increased transparency on chemicals of concern will help consumers make more informed decisions and improve waste companies’ recycling processes.
If you have Substances of Very High Concern (SVHCs) with a concentration above 0.1 mg/kg per material in your products, you are required to report this since 5 January 2021 by entering the concentrations, the components and the test documents in the new SCIP database. In Germany, at present there is only an informal obligation to report to the ECHA pursuant to Section 16f of the Chemicals Act (ChemG), which does not include the obligation to actually use the SCIP database. It remains to be seen how long this German path can be maintained. If you wish to set up your business in a future-proof way or sell your products to other EU countries, you will probably not be able to avoid using the SCIP database.
Are your products SVHC-free? You will only know this once you have valid test documents in hand. However, many products can already be seen to contain SVHCs. Examples are products with aluminium or brass alloys, with plug contacts or certain electronic components.
The new transparency of the publicly accessible SCIP database is a real invitation to establish whether such products are on record in the database. Both market participants and regulatory authorities can give you cause for concern when you take this path. Whereas product managers previously only responded reactively, they are consequently now obliged to ensure prevention.
Do not push your luck - take action now! The trade-e-bility team will support you with advice on the choice of the economically reasonable means all the way through to entering the reports in the SCIP database. If you have any questions, please do not hesitate to call trade-e-bility on +49/40/75068730-0 or send an e-mail message to beratung@trade-e-bility.de.
