The requirements for the compilation of safety data sheets are now set out in Annex…
From 5 January 2021, every manufacturer, importer or distributor, who places on the market a product containing more than 0.1% of substances of very high concern (SVHC) is obliged to provide information on this to the so-called SCIP database.
SCIP stands for Substance of Concern In articles, as such or in complex objects (Products). Exceptions apply to retailers who only sell goods directly to consumers, such as stores.
The provision on notification to the SCIP database already exists in the EU Waste Directive.
What is an article?
An article in accordance with Article 3.3 under REACH is defined as “…an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition.”
The legislator has deliberately chosen to use the extended term “article” as a generalisation of both goods as such and complex objects. Possible product is either a component (e.g. blade, one-piece plastic spoon, O-ring) or a complex object (e.g. pencil sharpener, armchair, vehicle engine, electronic equipment). It also refers to components in a product (the screw, blade and cover are components in a pencil sharpener). An article can also be a component of a larger article (o-rings in an internal combustion engine, which in turn is part of a motor vehicle). One article can also be processed into another article (metal strip can be processed to make metal sheets).
What implications does it have for you?
If you sell directly to consumers, you do not need to do anything. However, if you are a manufacturer, importer or distributor, it is time to:
- review your assortment;
- see what information about the content of your goods is missing;
- create a questionnaire and contact the supplier for further information;
- create action list and action plan;
- review the budget section.
What should the notification contain?
- information on the identity of the product;
- the name of the substance, concentration and where in the product the substance is present;
- Information on how to handle the product safely.
See also: SCIP database notifications
Why this legislation?
According to the information provided on ECHA the three main objectives of the SCIP database to support the circular economy are the following:
- Decrease the generation of waste containing hazardous substances by supporting the substitution of substances of concern in articles placed on the EU market.
- Make information available to further improve waste treatment operations.
- Allow authorities to monitor the use of substances of concern in articles and initiate appropriate actions over the whole lifecycle of articles, including at their waste stage.
The primary goal still remains the substitution of the Candidate List substances of very high concern in articles with safer alternatives, and thus preventing the generation of waste containing those hazardous substances.
When is the database ready?
The final version of the SCIP database is scheduled to be launched in October 2020. Before that, you have the opportunity to test it and submit comments to ECHA. The information in the database must be made available to waste operators and consumers.
The updated ECHA submission portal allows you to send a simplified SCIP notification. If an industrial supplier has already provided information about the same product to the database, you as a distributor can merely link to this notification. This can significantly reduce your workload.
How do you register?
To be able to create a registration dossier, you must first have access to ECHA Cloud Services, which can be accessed from https://echa.europa.eu and create an account there. Then you need to enter a legal entity that will be connected to your account (usually it is your company). Then you can choose whether you want to create your material directly online or do it separately. You do this by uploading the platform to the company’s own IT infrastructure, and then uploading it to your account.
See also: ECHA Accounts Manual
You have access to both the candidate list and already registered products to facilitate the process. All detailed information about the application from the creation of documentation to the submission confirmation can be found here.
How can we help?
- Review your products and create an evaluation and action plan.
- Analyze the product information and information systems that your company uses.
- Create an action plan for continuous registration.
- Help with the registration.
Do not hesitate to contact us for more information or consultancy.