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SCIP Database seeks the alignment with its own legal grounds

APPLiA on the challenges posed by the current implementation of the SCIP Database.

The SCIP Database is a “data bank” of Substances of Concern In articles, or in complex objects (Products) under the Waste Framework Directive. The legal requirement demands companies that supply articles1 to submit information on these to ECHA, the European Chemicals Agency. The data would then be made available to waste operators, and consumers upon request. Starting date: 5 January 2021.

However, the current ECHA implementation poses multiple challenges, not only to the home appliance sector, but to the entire European industry.

“The implementation of the SCIP must be aligned with its legal requirements, and currently that is not the case” commented Paolo Falcioni, APPLiA’s Director General during the 4th Edition of the Material Compliance Series conference organised by the TBM Group. The reference was made to the fact that the current implementation of the Database trespasses Article 33(1) REACH, practically overstepping the legal requirements laid down in the same Article. In practice, it is not possible today to submit a SCIP notification without adding elements which should be optional but are, on the contrary, considered to be mandatory.

On top of that, the washing machine we have at home is the outcome of a complex and global supply chain. Along the process, many actors provide the parts to build up the final product and those components are the result of structured manufacturing chains in turn. In practice, the SCIP notification of a washing machine, for example, would refer to the SCIP notifications of its components. “Who would be held responsible if some parts are not SCIP notified?” asked Paolo Falcioni to highlight one of the leaks of the system. “Not to mention”, he continued, “that there can be multiple suppliers of the same component and it may happen that during the manufacturing process a different supplier would have to be selected.” The huge complexity of the European industry is intrinsic and must therefore be taken as a starting point before any tool can even be conceived. In addition to that, the complexity in establishing the aforesaid Database is translated into enormous costs that are to be added on the shoulders of the European industry.

A correct implementation of the SCIP Database must be aligned with its legal grounds, as found under Article 9(1)(i) of the Waste Framework Directive, and further in Article 33(1) REACH. A postponement of the SCIP does not represent a real solution, as the existing trespassing of requirements would still show up at a later moment in time.

 

1 Articles subject to the legal requirements are the ones containing the substances on the so-called “Candidate List” in a predefined concentration by weight and that are placed on the EU market.