On 21st September 2020, a group of 40 different industry associations sent a letter to the European Commission President Ursula von der Leyen requesting that the deadline for reporting to the new Substance of Concern in Products (SCIP) database is postponed by at least 12 months.
The requirement to report is based on the Waste Framework Amendment Directive (EU) 2018/851 in order to regulate circular economy requirements. It requires that from 5 January 2021, producers and importers must report information on articles or products containing Substances of very High Concern (SVHC) in a concentration > 0.1% by weight placed on the market to the European Chemicals Agency (ECHA) through the SCIP database.
With this deadline fast approaching, this letter calls for urgent action to be taken by the EU Commission to:
“1. Postpone the SCIP notification deadline of 5th January 2021 by at least 12 months after the database will be finalized;
2. Conduct a study on the usefulness, feasibility, proportionality and impact of the database, and;
3. Instruct the ECHA to adapt the SCIP database according to the outcome of such study.”
This letter shows the discontent of numerous powerful industry sectors across the EU who believe that ECHA has failed to finalize development of the database to the required timescale of January 2020. This delay has prevented companies from developing, testing and adapting their own systems to meet the January 2021 notification deadline.
Although the signatories have repeatedly expressed their serious concerns over the last 2 years on the workability, proportionality and value of the SCIP to the EU Commission and ECHA, they believe this has fallen on deaf ears.
Furthermore, the fact that the reporting requirement was introduced by Directive (EU) 2018/851 without any prior stakeholder consultation or impact assessment has really caught industry off-guard. They believe that a proper impact study should help shape the way forward to deliver on the EU ambition for a circular European economy.
You can read the press release on the Letter to EU Commission here.
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