The goal to look from all angles at upcoming regulatory requirements and possible solutions for the notification of products (including the notification to the SCIP database) was achieved for sure at the opesus Product and Poison Centres Notification Virtual Conference 2020 on May 18th and 19th. Attendees got informative contents, interesting presentations and enjoyed the relaxed course of the whole event. Since almost all the 140 participants stayed online until the very end of the Q&A and collaboration sessions, a large part of the current questions on the topic could be collected and answered. Read more
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
The revised Waste Framework Directive (WFD) requires the establishment of a database for information on substances of concern in articles as such or in complex objects (products) (SCIP). The goal of this database is to improve the transparency on hazardous substances in articles for waste operators, authorities and consumers. Read more
On 17th March, ECHA held a webinar where they introdcued the SCIP database prototype. With more than 250 people listening in, the webinar was very well attended. The prototype of the SCIP database was released a month ago to allow duty holders to familiarize themselves with the process of preparing and submitting dossiers in a test environment. Read more
At a working group meeting of the working group “legally compliant environmental management”, Andreas Müller presented on the ECHA SCIP Database. As the opesus expert on the upcoming SCIP requirements, Andreas covered the regulatory requirements and included tips on how companies can start preparing for the upcoming deadline. Read more
Under the Waste Framework Directive (WFD), the European Chemicals Agency (ECHA) has developed the SCIP Database designed to capture information on articles containing substances of very high concern (SVHCs) on the REACH Candidate List. This requirement of submitting information poses a significant challenge to companies to efficiently comply with their reporting obligations. We are excited to announce that our software, opesus EHS Product Notification, will support companies that are required to submit notifications to the SCIP database. Read more