New Substances of Concern in Products (SCIP) Database

• United Kingdom

• Environment
• Industrials - Chemicals

25-02-2020

Do you import or otherwise place products on the EEA market? If so, you should be aware of the new European Chemicals Agency (“ECHA”) SCIP database.

Companies placing products (articles) on the EEA market, including companies importing such products, which contain substances of very high concern (SVHCs) above 0.1% by weight will, from 5 January 2021, have to submit information on those products and SVHCs to ECHA through the SCIP database.

The purpose of the SCIP database is to promote the substitution of hazardous chemicals and the transition towards a safer circular economy. It will enable information on products containing hazardous substances to be available throughout the whole lifecycle of the product, including the waste stage. The information in the SCIP database will be made available to waste operators and consumers.

ECHA has released a prototype of the database so that companies can become familiar with how notifications will work. A final version of the SCIP database will be launched later in 2020 (likely October 2020). Information submitted to the prototype will be considered as test data and will be deleted before the final SCIP database is released.

The prototype database gives an indication of the level of information which will be required to be submitted by companies including:

0. information to identify the article;
0. the name, concentration range and location of the SVHC in the article; and
0. other information on its safe use.

Information in the database will need to be kept up to date particularly as the list of SVHCs is updated regularly (bi-annually generally in June/July and December/January). The prototype database also includes a section to update a previously notified article to confirm that it no longer contains a relevant SVHC.

There is no cost to submitting a notification however, there will be an administrative cost involved in collating and submitting the information required for a notification. Those importing and placing products on the market should already be aware of whether they contain any SVHCs in order to comply with their existing obligations to pass this information to professional users in their supply chain, and to consumers on request. However, many companies are unaware of whether or not their products contain any SVHCs in relevant quantities and/or are unfamiliar with these obligations. Given the new SCIP database requirements it is timely for companies to reconsider their products, and the information they have in respect of them.