The European Commission and European Chemicals Agency (ECHA) have confirmed that the January 5, 2021, submission deadline for the Substances of Concern In articles, as such or in complex objects (Products) (SCIP) database will remain in place. This comes in spite of requests from an industry group to delay the EU Waste Framework Directive (WFD) requirement by 12 months.
On October 1, 2020, Chemical Watch reported on the commission’s response to the delay request, stating that “the Commission said the 5 January deadline to begin submitting information still stands.”
The delay request had urged European Commission president Ursula von der Leyen to take “urgent political action” that included a one-year delay for the submission requirements. It also asked the European Commission to reevaluate the efficiency of the SCIP database, including its “usefulness, feasibility, proportionality, and impact.”
Learn more about your new EU market access requirements in our eBook, Understanding the EU Waste Framework Directive & SCIP Database Reporting.
European Commission & ECHA Stand Firm on EU Waste Framework Directive Requirements
The European Commission’s response indicated that industry has had sufficient forewarning of their requirements, and that the deadline has been set since May 30, 2018. It also said that member states and stakeholders have been “extensively consulted throughout the process.”
The industry association’s letter was challenged by the European Environmental Bureau and ClientEarth, whose own letter to von der Leyen asked her “not to cede to industry demands,” and that it would be “undemocratic and illegal for the commission to defer the entry into force of an obligation that the co-legislators set with a specific deadline, or to weaken the obligations they created in any way.”
This position was supported by over 49 other non-governmental organizations (NGOs). This indicates that failure to meet SCIP database submission requirements could lead to additional reputational damage for non-compliant companies.
This could affect a lot of companies. On November 6, 2019, ECHA published results of an enforcement pilot conducted between October 2017 and December 2018. The findings revealed that 12 percent of the articles inspected contained Candidate List substances above the 0.1 percent weight over weight (w/w) threshold, and 88 percent of those failed to submit the right data to customers.
The Implications of the SCIP Database for Companies
The SCIP database is the first digitally available enforcement mechanism of its kind, and it marks a new era of regulatory compliance — one driven by data and public transparency. Starting in January 2021, enforcement agents will be empowered to hold companies accountable for the responsible handling of each individual component in their products, from the raw materials stage to end-of-life recycling or disposal. Estimates suggest that it could cost companies manufacturing or selling in Europe over €67 billion per year to collect, prepare, and submit the data required to meet the new reporting obligations and ensure continued access to EU markets.
Preparing for the SCIP Deadline With Assent
As the leading supply chain data management software, the Assent Compliance Platform organizes, streamlines, and automates the complex SCIP database submission process, enabling the world’s largest enterprises to digitally manage data across their supply chains and meet SCIP database requirements through our patent-pending solution.
Raj Takhar, Assent’s Senior Subject Matter Expert of Materials Compliance and Chemical Reporting (Europe), is part of an industry working group advising the European Chemicals Agency (ECHA) on the database.
“A manual approach to data submission is simply not feasible for most companies,” said Takhar. “Each part could require hundreds, if not thousands, of database submissions, and some products have thousands of parts. The scale of this is monstrous and nearly impossible to manage without help.”
Assent is the first supply chain data management company to complete an automated SCIP database submission on behalf of a client. For free educational resources and tools to help your company understand and meet your data exchange requirements, visit the SCIP Registration Center.
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