New EU Regulation for Notifying Products Containing Environmentally Hazardous Substances.

As from January 5, 2021, all companies that manufacture, import and distribute articles with substance of very high concern on the Candidate List in a concentration above 0.1 % w/w placed on the EU market, needs to register those in a new database called SCIP: Substances of Concern In articles as such or in complex objects (Products).

FiloProcess has many years of experience within the product information area. Therefore we have developed a simple offering where we help companies understand, map and solve an information structure that meets the new reporting requirements in a long-term way.

 

The obligation comes from the European Commission and is governed by Waste Framework Directive (WFD) Article 9(1). The European Chemicals Agency, ECHA was commissioned to establish and manage the database. All suppliers of an article containing SVHC are covered by the obligation to provide information to ECHA. Suppliers outside of the EU are not subject to this obligation, however, they are encouraged to contribute to the best of their ability.

In addition to existing obligations within REACH, SCIP extends the REACH Article 33 duties of suppliers of articles to communicate information about the presence of substances of very high concern (SVHCs) on the Candidate List in their articles, by requiring them to submit that information also to the SCIP database maintained by ECHA. The obligation was implemented in swedish national law August 1st 2020.

The rule 0.1% w/w applies to the weight of an article, not the total weight of a product (a so-called complex object) that an article is included in. An example could be a drill (complex object) containing a screw (article) in turn contains an SVHC. Then the supplier of the screw should report the screw, but also the manufacturer of the drill must report the drill, because it contains a screw with SVHC. Hence the manufacturer of the drill can choose to refer to the already reported screw information.

The purpose of SCIP is to prevent adverse effects on the environment and human health by reducing the amount and replacing hazardous waste. This is also an action to improve the conditions for waste management in order to empower the transition to a circular economy. This is now done by securing available information on environmentally hazardous substances in products and materials throughout the life cycle, including the waste stage. The SCIP database will also be available to consumers. An app (the Chemical App) has been developed where anyone can request information about products by simply scan the EAN codes of products.

At FiloProcess, we understand this is a major challenge for many actors in the supply chain. How to relate to this, find information, what it means in practice and where to start. This is not a one-off effort, but activities that must be maintained over time. Therefore a solutions are required that both affect- and need to be integrated into the existing information flow and a company’s processes. We have many years of experience within the product information area such as mapping and analysis of which gives us the knowledge to help our customers with SCIP. We provide a free 30-minute online introduction (due to covid-19). If there is a need for our help, we start an initiative that is executed in three phases: Analysis, Solution and Implementation.

For more information do not hestitate to contact us or our CEO, Bengt Sareyko.

+46 70 779 47 85  I  bengt.sareyko@filoprocess.se  I  Contact