Since 5 January 2021, the obligation to submit data on substances of very high concern (SVHCs) in articles has been applicable in accordance with the Waste Framework Directive 2008/98/EC. The new requirements affect all companies placing articles containing substances of very high concern from the candidate list on the EU market.
The increased transparency on chemicals of concern is to help consumers make more informed decisions and improve waste companies’ recycling processes.
If you have Substances of Very High Concern with a concentration above 0.1 g/kg per material in your products, you are required to report this as of 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 under 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 GmbH team supports you: with advice on the choice of the economically most reasonable means all the way through to entering the reports in the SCIP database.
The consultancy team from trade-e-bility will be pleased to assist you. Please call +49/40/75068730-0 or send an e-mail message to beratung@trade-e-bility.de.
Further particulars:
Know more about hazardous chemicals in products – SCIP data published
