A Complete Guide to the EU Waste Framework Directive and the ECHA SCIP Database
This introduction provides you everything you need to know about the Waste Framework Directive (WFD) and the SCIP database. For companies that are affected by the requirement, this guide also covers solution options.
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This guide is a comprehensive starting point about the SCIP database and what you should do to get started and answers the following questions:
- What is the EU Waste Framework Directive?
- What is the Candidate List of Substances of Very High Concern (SVHC)?
- Is my company affected by the SCIP database?
- What are the data requirements for SCIP database notifications?
- How to create and submit SCIP notifications?
- How to start preparing for SCIP notifications?
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The EU Waste Framework Directive
The Starting Point for the SCIP Database
The Waste Framework Directive (Directive 2008/98/EC) is the legal requirement behind the SCIP database. The Waste Framework Directive has the overarching objective to support the European Union's transition to a circular economy. The measures of the directive aim to prevent or reduce the harmful effects of waste generation and management on the environment and human health. The main goal of the WFD legislative framework is to ensure a harmonized, safe and secure management of industrialized material waste and promote efficient use of resources.
In the amended Waste Framework Directive, which entered into force in July 2018, the European Chemicals Agency (ECHA) was tasked with establishing a database with information on articles containing substances of very high concern (SVHC) as per the REACH Candidate List. This database is called the SCIP Database (Substances of Concern In Articles As Such or in Complex Objects (Products)).
The SCIP database gathers all collected information about articles containing Candidate List substances and aims to improve transparency on hazardous substances in articles to the end consumer, authorities, and waste operators.
- For a detailed look at the topic of Waste Framework Directive, see https://ec.europa.eu/environment/topics/waste-and-recycling/waste-framework-directive_en
- For the legal text of the Waste Framework Directive, see https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02008L0098-20180705
What is the Candidate List of Substances of Very High Concern (SVHC)?
Substances of very high concern (SVHC) are chemical substances that may be subject to authorization under the REACH regulation. A substance may be considered an SVHC if it is carcinogenic, mutagenic, toxic for reproduction, is persistent, bioaccumulative and toxic (PBT substances), is very persistent and very bioaccumulative (vPvB substances), and if there is scientific evidence of its probable serious effects to human health or the environment. These substances are compiled in a list known as the Candidate List. This list was first published in October 2008. The most recent update was in June 2020 bringing the total number of SVHCs to 209.
This list is referred to as a "candidate list" because all of these substances have the potential to be included in Annex XIV of REACH. Once a substance is added to Annex XIV, the substance cannot be used or imported into the EU without authorization from the ECHA.
For SCIP Database notifications, articles containing SVHCs according to the ECHA Candidate List in a concentration above 0.1% weight by weight on the EU market must be notified. Through the SCIP database, information about articles containing Candidate List substances is available throughout the whole lifecycle of products and materials.
- For a complete list of substances of very high concern on the ECHA Candidate List, see https://echa.europa.eu/candidate-list-table
Is my company affected?
If you are supplying an article, as defined by REACH Article 3 (33), to the EU market that contains a Candidate List substance in a concentration above 0.1% weight by weight have to submit a notification to the SCIP database. This includes
- EU producers and assemblers
- EU importers and distributor
- Any other actor in the supply chain that places articles on the EU market
Data Requirements for SCIP Database
Suppliers of articles that are affected by the SCIP database requirement must submit the following information to the SCIP database:
- Information to allow the identification of the article such as name, primary identifier, etc.
- Information on the concern element, i.e., the name, location and concentration range of the Candidate List substance(s) present in the article
- Information to allow the safe use of the article, particularly in the waste stage.
This snapshot of information is collected into an i6z file, or for a less technical term, a dossier. This dossier is then submitted to the SCIP database. Once submitted, you will receive a UUID or the SCIP number for that dossier.
If you're worried about how the SCIP database manages your data, see our article on Protecting Confidential Business Information.
How to Create & Submit SCIP Notifications
ECHA provides different methods for companies to prepare their submissions:
- online in IUCLID cloud
- offline in IUCLID software
- using a IUCLID-compatible dedicated format for SCIP submissions from the company's system
After preparing the information, you can submit the SCIP notification manually by uploading it directly in the ECHA Submission portal or automatically via system-to-system (S2S) submission. This is only possible if you use a IUCLID-compatible software in your company's system and enable the S2S communication between your system and the ECHA submission portal.
If you are not sure which tool is best suited for your needs, check out the article linked below.
Substances with hazardous properties, i.e., classified as carcinogenic, mutagenic or toxic for reproduction (CMR), bio-accumulative and toxic (PBT) and very bio-accumulative (vPvB), or on a case-by-case basis that can cause equivalent levels of concern as CMR or PBT/vPvB substances.
An object that cannot be dismantled into parts. Articles keep their shape, surface or design. But, they can contain several materials. For example, the bicycle frame.
- Complex Object
An object that is made up of two or more articles. In other words, several articles can be joined together to create a complex object. For example, a bicycle.
Which tool to use for SCIP database notifications?
Where to begin?
Steps to Preparing SCIP Notifications
We get asked this question a lot. Before you explore various software solutions such as opesus EHS Product Notification for SCIP Database, here are a few steps that you can start with:
- Analyze your portfolio for affected products.
Check the total number of products or articles that are affected by the SCIP database. Having this number in mind gives you a better estimation of the effort required.
- Evaluate the completeness of data.
Check the data that you have on your articles and products against the data required for SCIP database notifications. You may have to reach out to your suppliers and manufacturers to get additional information about particular parts, etc. There are several advantages to reaching out to your supply chain as described here.
- Decide how to handle SCIP notifications.
With the information that you've collected, estimate the total effort required in terms of time and resources. A good question to ask is: How can you best handle SCIP notifications with the available resources? If you only have a handful of affected products, you might choose to handle SCIP notifications manually. If these products are updated or changed frequently, getting an IT system is probably the most efficient way to handle these changes.
- Evaluate solution providers.
There are a few solution providers on the market for creating SCIP database notifications. This is a good time to get someone from your IT department involved to find out which solution provider best fits into your company's IT system landscape and security requirements. If you have an approved budget at this point - even better!
- Implementation timeline.
The compliance requirement of the SCIP database kicked in on January 5th, 2021. If you are just getting started, work with your team to create a prioritization list of articles in your portfolio. Your IT solution provider should work with you on the best strategy for managing and submitting SCIP database notifications as efficiently as possible. If you already started submitting notifications, you probably are looking at improving the process using IT solutions. There are several solutions out there with various capabilities. For example, opesus EPN for SCIP Database Format has the most process automation features that allow you to easily manage change management and stay on top of your SCIP database notifications.
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