Today we will talk about another new development in chemical legislation, entering into force on 5 January 2021.
This new development is the reporting on SVHCs in articles to the SCIP Database.
SCIP is an English abbreviation for Substances of Concern In articles, as such or in complex objects (Products).
The goal of collecting the data on SVHCs in articles is to enable competent authorities to monitor the use of SVHCs in articles and to implement suitable measures for the full life cycle of such products, including at the waste level.
That is why the European Chemicals Agency (ECHA) intends to establish and maintain a database, containing information provided on SVHCs in articles as such or in composite items (products). Thus, this new development does not apply to classical chemicals (pure substances or mixtures), but to articles.
An article in this instance means an item taking a special form or surface during production, which determines its function more than its chemical composition.
ECHA will make this information from the SCIP Database available to all waste managers and consumers.
What does the above mean for you?
If your sales program contains articles, you must verify if these contain SVHCs. And if you determine the presence of SVHCs in your articles, you may become liable for reporting to the SCIP Database.
Duty holders to report on SVHCs in articles are namely article suppliers, which are:
- article manufacturers and assemblers in the European Union,
- importers of the articles into the European Union,
- distributors and other subjects in the European Union within the supply chain, placing articles on the market. These can reference the information already submitted by their supplier to prevent dual reporting.
The obligation to submit information to ECHA, however, does not apply to retailers and other actors within the supply chain, providing articles directly to consumers.
This obligation to report on SVHCs in articles to the European Chemicals Agency (ECHA) shall enter into force on 5 January 2021. With this the obligation to submit the application covers articles, placed on the EU market, containing SVHCs (from the candidate list for authorization) in a concentration higher than 0.1% w/w.
The chemical legislation is constantly changing. Monitoring these changes requires a great deal of time and timely preparation.
You can always contact us for help if you do not have enough time to monitor and implement these changes. We are only one phone call or e-mail away.