On September 9, 2019, the European Chemical Agency (ECHA) provided the specification with information requirements for the WFD (Waste Framework Directive) Database that manufacturers will need to use to submit information on SVHCs in their products. ECHA is now referring to this as the SCIP Database. Manufacturers whose products are sold into the EU and contain an SVHC — which is true for most EEE products and large machinery, vehicles, etc — will need to submit information about their products into the database or provide information to importers/distributors for submission. The submission duty becomes mandatory as of January 5, 2021.
In the latest document, ECHA has modified some of the terminology that was used in earlier proposals, but otherwise the technical data requirements are similar to an earlier draft specification from May 2019.
The information requirements require manufacturers to submit information about the overall product (complex object) and the first article/component containing the SVHC (ECHA is now referring to this first article as “Article as such”). ECHA has summarized the requirements as:
Besides administrative contact details, suppliers of articles need to provide the following information to ECHA:
- information that allows the identification of the article;
- the name, concentration range and location of the Candidate List substance(s) present in that article; and
- other information to allow the safe use of the article, notably information to ensure proper management of the article once it becomes waste.
ECD Compliance has been providing comments to ECHA on the data requirements, material categories, and IT system on behalf of our clients. We will continue to provide input as the database is developed and to participate in ECHA SCIP User Groups.
We are already working with our clients (manufacturers, suppliers and solution providers) to help setup supply chain communication, IT systems and data collection in preparation for the January 5, 2019 deadline to meet the obligation. Starting the process as soon as possible is critical to success and on-going compliance with EU regulations. Contact ECD Compliance to discuss how we can help your organization.