SCIP database is developed under the Waste Framework Directive to take a step towards a circular economy. With the SCIP database, the product lifecycle is completed with information on substances of concern in articles. One of the things that is a hot topic of discussion is dissemination of information and protecting confidential business information (CBI).
SCIP: Who will get access to the submitted data?
From 5 January 2021, suppliers of articles are obligated to submit notification to the SCIP database. The SCIP database is accessible by the following groups of people:
- Waste Operators
Information in the SCIP database are meant to support compliant re-use and increase recycled materials.
One of the purposes of the SCIP database is to empower consumers to make informed choices on purchasing and to assist them in disposing articles safely.
Authorities can access the data in the SCIP database to assist them with regulatory actions such as to monitor SVHCs and address any required regulatory actions. Additionally, they could use the available information to support waste policy decisions.
As the SCIP database does require quite some detailed information, it is naturally a concern for many companies who are affected by the SCIP requirement.
How does ECHA protect my confidential business information (CBI)?
The central element in the protection of CBI is to avoid the disclosure of links between the actors in the supply chain and information on supply sources. The information required to be submitted to the SCIP database can generally be structured into four categories of information: article identification, concern elements, safe use information, and other . According to the presentation on CBI by ECHA, all these categories of information will be available on the SCIP database except for the following elements:
- The link between the notification and its submitter, i.e. legal entity.
- In case of submissions for complex objects, only the identifiers and names for the top level article, i.e., the complex object, will be disclosed. For its complex object components, only the name and the article category are disclosed.
Get information on what companies can do to protect CBI at our conference
With the steps that ECHA takes, companies should have a clear strategy on what and how to report their data. Especially that which will be publicly accessible. For example, ensure that none of the free-text fields, disassembly instructions, etc. that you provide in a SCIP submission contain confidential business information.
What can your company do to protect CBI? How can you manage this information within your SAP system? These are just some of the questions that our upcoming conference will explore. Join us!
- ECHA’s slide deck on SCIP and CBI: https://echa.europa.eu/documents/10162/28213971/scip_cbi_en.pdf/f3fa94cc-e2b2-b3d4-f904-2243340e2ef8