SCIP database of articles containing substances of very high concern - Chemical Watch Regulatory Summit Europe - 14 October 2019 Kevin Pollard ...
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SCIP database of articles containing substances of very high concern Chemical Watch Regulatory Summit Europe – 14 October 2019 Kevin Pollard Head of Unit Exposure and Supply Chain Unit
Background
SCIP Database-Background
EU action plan for
the Circular
Economy
Legal basis:
Waste Framework Directive
(WFD)
Establish and maintain a
database
for info communicated down in
the supply chain on substances
in articles
3
Revised Waste Framework Directive
Directive 2008/98/EC (WFD)
Article 9(1)(i): “any supplier of an article as defined in point 33 of
Article 3 of [the REACH] Regulation provides the information
pursuant to Article 33(1) of that Regulation to the European
Chemicals Agency as from 5 January 2021”
Note: One of the conclusions of the Pilot Enforcement Project on
Substances in Articles (REACH Art. 33) coordinated by ECHA’s
Enforcement Forum (Oct. 2017- Dec. 2018) is that communication trough
the supply chain needs to be improved. A final report of this project is
expected to be published by end of 2019.
Article 9(2): ECHA ”shall establish a database for the data to be
submitted to it pursuant to point (i) of paragraph 1 by 5 January
2020 and maintain it. The European Chemicals Agency shall
provide access to that database to waste treatment operators.
It shall also provide access to that database to consumers upon
request.”
4
Scope
• Substances on the Candidate List, i.e. identified as
Substances of Very High Concern (SVHC)
when incorporated into
• An ”Article” (in a concentration above 0,1 %
weight by weight (w/w))
→ Duty to supply sufficient information to
allow safe use of the article (Art. 33(1) REACH)
5
Article & Complex object
Article Complex Object
An object
which during
production is Articles are assembled
given a special
together into
shape, surface
or design which “Complex objects”.
determines its
function to a
greater degree
than does its
chemical
composition.
6
From articles to complex objects
Articles are usually assembled together into
(very) “complex objects”:
1 article 10s-100s 1,000s articles
articles
Article suppliers Waste operators /
supply “individual” consumers deal with
articles complex “assemblies”
7
SCIP database
SCIP database - Objectives
Reduce the content of hazardous substances in materials
and products, including recycled materials
Push for substitution of
substances of concern and
prevention of (hazardous)
waste generation
Contributing to a
Increase authorities'
more circular
information basis on
economy: improve
substances in
waste treatment
articles
operations
9
Roles and milestones
4 July 2018 Q1 2020 5 January
5 July 2020 2021
Entry into ECHA
force of database Member State Suppliers of
Directive (EU) established transposition articles submit
2018/851 info to ECHA
• Establish a database + Enable submission of info by EU
suppliers of articles
• Provide access to the database to “waste treatment
operators”, and to consumers (upon request)
• Transpose into national law
MSs
• Enforce
10SCIP- duty holders
Any supplier of articles containing above 0.1% w/w of a
substance of very high concern on the Candidate List
EU producers & Importers
5 January
2021
Duty holders
Assemblers need to
submit info
to ECHA
Distributors*
* Except retailers that supply directly and exclusively to consumers
11SCIP – Info requirements
Substance of
Article concern (SVHC) in
Identification the article
(Concern element)
Safe use
information
- Identifiers
- SVHC identifiers
- Name
- Concentration range
- Article category
- Material category
(TARIC/CN code)
Detailed information requirements published on ECHA website
12SCIP – Notification “dossier”
Car (Identification)
wheels
Safe use IUCLID
Engine
4
+ instructions = Dossier
1
O-rings 4
Article
+ Safe use + Concern
Identification instructions element
13SCIP database flow
Storage Dissemination
Data submission
SCIP database
Manual
upload of
file
Duty Manual
holders preparation
(Article online
suppliers)
Publication of the information
as received (duty holder
System to
responsibility for submitting
System
accurate data)
14Dissemination
SCIP database
Waste operators Authorities
Available info to ✓ SVHC monitoring to
✓ drive waste stream address regulatory
decisions Consumers and other actions
✓ support compliant ✓ Available info to
interested parties support (waste)
re-use
✓ increase recycled ✓ Empower informed choices policy decisions
materials ✓ Improve targeted disposal ✓ Support
enforcement
No confidential business information disclosed
15SCIP - more information
available on imported articles
Data
Supply chain submission
communication
Non-EU Importers
suppliers
SCIP database
New task for
Importers
Provide ECHA
information to
Imported articles allow article safe
use
16ECHA Project status: IT
• IT development in progress for release of a
”prototype” version early 2020
• Detailed information requirements for SCIP
database published on ECHA website on 9
Sept. 2019
• Technical format for data submission to
published by end Oct. 2019 (”IUCLID” format)
17Stakeholder engagement
• Direct consultations of interested stakeholders
(incl. European Commission and MSs)
• Numerous meetings & speaking engaments
• SCIP IT user group just started
• Next SCIP stakeholder workshop at ECHA
18SCIP Workshop
Where & When?
• At ECHA
• 12 November
• The workshop will be web streamed
Key issues
• State of play of the project and IT implementation of the SCIP
database;
• break-out discussions on efficient notification procedures; and
• how to make the data available to waste operators and
consumers.
Interested?
• Additional info and registration is available at ECHA>Events
19SCIP IT user group
Aims
• Engage the user community in the development of the system.
• Gather improvement ideas.
• Identify the areas where extra attention is needed in order to provide
adequate support/guidance.
Activities
• IUCLID format revision
• IUCLID & S2S testing
• Additional working topics (e.g. reporting/dissemination, eficient
notification procedures)
Members
• ~30 representing companies, associations and service providers.
Periodicity
• Monthly virtual meetings on 2019.
• Monthly- biweekly meetings expected 2020
20How to get prepared?
Adapt your
1 2 3
Know
4
Know your Know data &
information your
obligations Prepare your
requirements portfolio
submission
Articles with CL Identification
substance >0,1 Concern Element
% w/w
Safe use info
Duty holders:
Producers &
Importers
Assemblers &
Distributors
System to
System
21Take aways
✓ Prototype of SCIP database available early 2020
for testing
✓ During 2020 further development and work on
dissemination portal
✓ Notification duty from 5 January 2021
✓ Information requirements available on ECHA’s
website to allow companies to prepare well in
advance
22Thank you! scip@echa.europa.eu Subscribe to our news at echa.europa.eu/subscribe Follow us on Twitter @EU_ECHA Follow us on Facebook Facebook.com/EUECHA
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