EU Waste Framework Directive SVHC Database

The European Chemicals Agency (ECHA) has published details of the SCIP (Substances of Concern In Products) database. ECHA plan to launch a prototype version in early 2020 and notification obligations for industry begin on 5th January 2021. Detailed information on what will be required has been published which lists the mandatory information that will need to be input to the database as well as the optional additional information.

The database will require manufacturers, importers and suppliers of articles that contain >0.1% of an SVHC (in a simple article) to provide information. The required mandatory information is as follows:

• Article name – input free text, could be, for example “mobile telephone” (a complex article)
• Primary article identifier – this refers to the article in which the SVHC is present that is being supplied. According to ECHA, this can be: “Numerical or alphanumerical identifier assigned to the article as such or the complex object and identification of its type. The primary Article Identifier will be used to support the preparation of a notification. Type options: e.g. European Article Number (EAN); Global Trade Item Number (GTIN); Universal Product Code (GPC); Catalogue number; ECHA Article ID, part number”
• Article category – ECHA indicates that “TARIC” codes should be used
• Production in European Union – the duty holder is asked whether the article is made in the EU. Three options are available: yes, no, unwilling to disclose
• Safe use instructions – duty holders can input “No need to provide safe use information beyond the identification of the Candidate List substance”, if this is the case

Two questions apply only to complex articles. These are:

• Linked articles – ECHA states “Add a link to an existing article or create a new article or a complex object to link with this complex object”. The ECHA guidance shows that in the example of an O-ring that contains an SVHC in an engine of a vehicle, the notification for the vehicle is linked to the engine and to the O-ring
• Number of units – number of simple articles containing the SVHC that occur in the complex article

The next questions concern the identity of the SVHC:

• Candidate List version – i.e. year and month of publication
• Candidate List Substance – Name, EC and CAS numbers (when available) of the Candidate List substance selected from the Candidate List entries
• Concentration range – this is not required by REACH, but ECHA implies that this is a WFD requirement to determine whether waste is hazardous

Options are:

• > 0.1% w/w and < 0.3% w/w;
• ≥ 0.3% w/w and < 1.0% w/w;
• ≥ 1.0% w/w and < 10.0% w/w;
• ≥ 10.0% w/w and < 20.0% w/w;
• ≥ 20.0% w/w and < 100% w/w;
• > 0.1% w/w and ≤ 100% w/w. (Potentially, this could be used if the concentration is not known, which is likely as this information is not required by REACH, so is seldom provided by suppliers)

Only one of the following are required, the first for a single material, the second for a mixture:

• Material category – selected from list to be provided by ECHA
• Mixture category – identified using the European product categorization system (EuPCS)

To find out how you can stay on top of regulatory issues related to chemicals in products, sign up to our newsletter here.