SCIP database – our industry expresses concerns
The European Chemical Agency (ECHA) is defining a database for information on Substances of Concern In articles as such or in complex objects (Products) established under the Waste Framework Directive – SCIP database.
This database aims to inform waste treatment operators, national authorities and consumers on the presence of Substances of Very High Concern (SVHCs) as defined under the REACH Regulation 1907/2006.
ECHA published in September 2019 its detailed information requirements which clearly go beyond art. 33(1) reporting requirements in the REACH Regulation. This is a major concern for the construction equipment industry characterised by a complex and global supply chain. Therefore we urge the European Commission and Member States to restrict requirements to those under REACH art.33.
Additionally, the development of the database is imposing a tight timeline: the prototype of the first SCIP database should be tested by October 2020. The full implementation of the database will take place from the 5th January 2021. However, some crucial elements such as the notification mechanisms for complex articles with multi-source suppliers and the security and protection of data and trade secrets remain unclear.
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