by Source Intelligence
on August 21, 2020
Nearly 20 years ago, the EU expressed its conviction that a new strategy for chemicals policy was needed, one that could preserve the industry’s competitiveness while heightening the safety standards for human health and the environment. In a preamble to a voluminous white paper, the EU goes on to state that:
“Industries should become more proactive in terms of providing information and assuming responsibilities for its products.”
Since then, various chemical policies have been proposed, adopted, and amended. As of today, two main initiatives that govern the production, importation, and use of harmful chemicals in products on the European market are REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals) and the SCIP database submission.
Both regulations share common grounds, in particular with the use of REACH SVHCs (Substances of Very High Concern) list as a frame of reference and scope, but they vary in complexity.
In this article, we will compare the two in terms of duties and compliance requirements.
Entered into force in June 2007, the REACH regulation aims to improve the protection of consumers and the environment while encouraging businesses to find safer alternatives to harmful chemicals. The chemicals on the list of SVHCs may not all be hazardous but may have various impacts that users should be aware of.
For the sake of the comparison, we’re focusing specifically on REACH article 33, by which European manufacturers or importers must declare the presence of a substance of concern at a concentration of 0.1% (weight for weight) or above.
As long as companies provide sufficient information (at minimum the name of the substance) and instructions for safe use at the product level, there is no formal declaration template. Companies can submit declarations, safety data sheets, certificates, test reports, SDS etc.
The REACH regulation still requires some legwork in collecting and asserting data relevancy and accuracy, which can prove challenging when working with non-EU suppliers, but the registration process in itself is fairly straightforward.
Under ECHA’s mandate, the SCIP database is designed to not only inform users about the presence of SVHCs, but mostly assist waste management operators for safer handling during disposal or recycling.
The European Chemical Agency (ECHA) established the SCIP Database in the wake of the Revised Waste Framework Directive (July 2018) with the objective of working toward a more circular economy, as opposed to the traditional linear model of “take-make-dispose.”
In February 2020, ECHA published the first prototype of the database. So far, the project is on track to launch an enhanced prototype by October of this year. The deadline for businesses in scope to begin SCIP submissions for each of their products is January 5th, 2021, which is fast approaching.
Similar to the REACH regulation, manufacturers, assemblers, and importers into the EU must disclose substances of concern present at 0.1% w/w concentration and above. Where the requirements are far more complex is that it affects the simplest components that constitute the product (known as a complex product), i.e. parts that cannot be reasonably dismantled to a simple article.
The SCIP database will contain all substances listed on REACH SVHCs, though the required data covers larger grounds such as material identification, article number, HTS codes, number of components, and more.
So far, ECHA has updated the guidelines to build datasets several times and we expect there are more changes to come.
If your products are in the scope of REACH, you’re also affected by SCIP. Unfortunately, the data you gathered for REACH compliance is far from enough to meet ECHA’s database standards.
It has been a busy and taxing year adjusting to the supply chain disruptions brought forth by the pandemic. While for most – if not all – the remainder of the year seems cast in a hazy fog of uncertainty, it should be “almost business as usual.” This means that any deadline looming to bring your company to the expected level of legal compliance is not to be ignored or discarded as low-priority.
The main challenges in the next few months will be collecting and validating data, creating the datasets by component groups or product groups, and submitting to ECHA.
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What you regard as a daunting task and overwhelming project in view of your already stretched resources is one worry you can cross off your list.
Don’t ‘skip’ the SCIP database requirement. Rather, let us take care of it with you. Let us lift any uncertainties and concerns by showing you how our solution makes compliance easy. Request a demo of our SCIP Database Compliance solution today.