Companies in scope of the European Union (EU) Waste Framework Directive (WFD) are unlikely to get any additional time to prepare for their submissions to the Substances of Concern as such, or in complex articles (Products) (SCIP) database, says the European Chemicals Agency (ECHA).
Although the ECHA has received feedback regarding the difficulty of meeting the EU WFD’s more data-heavy requirements, it asserted that companies have had adequate time to meet these requirements.
“REACH Article 33 is an equivalent duty that has been in place for over ten years,” ECHA advised.
The European Commission concurred.
“The Commission continues to encourage companies to do what is possible to fulfill their legal obligations…they still have a number of months to prepare for the SCIP database notification obligation.”
While true that some companies in scope of the Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) Regulation already have some systems in place for meeting Article 33 communication requirements, they also need to collect, generate, and map new article data to complete their SCIP submissions.
They can then submit the data to the SCIP database either online, offline, or through a system-to-system transmission. Even if they already have REACH data, companies need expertise, process, and control systems to acquire and manage the additional EU WFD data, and create secure article dossiers that won’t reveal proprietary information. Doing this properly can create a business advantage when evaluators access the SCIP databas
What This Means for Your Company
The pressure on companies to report on substances of very high concern (SVHCs) continues to build. Just five days before the January 5, 2021, SCIP database deadline, the EU Market Surveillance Regulation will come into effect. Using the Union Product Compliance Network database, market surveillance agencies will be able to access centralized enforcement data from all member states. They will also gain access to the SCIP database, allowing them to zero in on non-compliant articles placed on the EU single market.
Source: Assent Regulatory Review