The European Chemicals Agency (ECHA) has announced the Substances of Concern In articles as such or in complex objects (Products) (SCIP) database will be in operation from January 5, 2021. After this date, businesses operating in the European Union (EU) must enter certain information onto the database if their articles contain a substance on the Candidate List at a concentration above 0.1% w/w.
The requirement applies to actors placing an article onto the EU market – EU manufacturers, assemblers, importers and distributors. It does not apply to retailers and other supply chain actors supplying articles directly and exclusively to consumers.
The Candidate List contains substances that have been identified as having hazardous properties, known as Substances of Very High Concern (SVHC).
The term SVHC is associated with the REACH regulation and includes substances that are:
- CMR – carcinogenic, mutagenic or toxic for reproduction
- PBT/vPvB - persistent, bioaccumulative/very persistent and very bioaccumulative
- Substances that cause an equivalent level of concern as CMR or PBT/vPvB substances, e.g. endocrine disruption
Stakeholders should note: the SCIP duty relates to the Waste Framework Directive and not REACH. Actors supplying directly to consumers are not bound by the SCIP duty but must still conform to the existing communication and notification obligations under REACH. This means suppliers of articles that contain a substance on the Candidate List above 0.1% w/w will still need to communicate to the recipient its existence, even if they are not required to submit such information to the SCIP database.
The SCIP database will require the following information:
· Administrative contact details (company information)
· Technical details:
o Information on the article as such or the complex object:
- Identifiers (name, brand, model, identifier (i.e. EAN), production in EU (yes/no))
- Characteristics (dimensions, weight, color…)
- Instructions (safe use, disassembling)
- For complex object components only: linked articles
o Information on the substance:
- Candidate List version
- Candidate List substance (name, EC and CAS number)
- Concentration range (select as appropriate)
Stakeholders are advised to now ensure they understand the requirements of the SCIP database to ensure continued compliance with EU regulations.
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