AEM member company DXC Technology is intimately involved with ECHA (European Chemical Agency) and is a leading participant in the technical reviews and validation in the definition and development of the incoming SCiP (Substances of Concern in Products) database, detailing substances of concern contained in products manufactured and sold in the European Union (EU). EU product producers and importers will need to begin SCiP database submissions on Jan. 5, 2021. The SCiP, as governed by the EU Waste Framework Directive (WFD), goes well beyond the product and substance reporting requirements set forth in REACh Article 33 [DXC].

The SCiP database is required by the EU Waste Framework Directive (WFD), and is being created as part of the EU’s commitment to embracing the circular economy, an economic system aimed at reducing – or even eliminating – waste and fostering the continual use of resources.

“As part of the EU Waste Framework Directive (WFD), companies are going to be held legally responsible to know what’s in the products they sell,” said Chuck LePard, senior consultant, product engineering, manufacturing, compliance and sustainability for DXC Technology. “If you manufacture or sell a product into the EU, you’re going to be required to report the chemicals of concern that make up the building blocks of the components that go into your final product.”

Objectives of the SCiP Database

The EU’s commitment to eliminating waste and the continual use of resources has led to the enforcement of the EU REACH (Registration, Evaluation, Authorization and Registration of Chemicals) regulation and RoHS (Restriction of Hazardous Substances) directives, so as to ensure product design efforts align with priorities associated with the circular economy. In addition, the revised version of the Waste Framework Directive serves to address end-of-life service activities. More, specifically, it helps ensure manufacturers remove harmful chemicals from their products and try to identify where they came from before the offerings make it to market. (See illustration above)

The European Chemical Agency (ECHA), in order to help facilitate enforcement of REACH, RoHS and the Revised Waste Framework Directive, are in the process of developing the SCiP database to document substances of concern. According to the ECHA, the SCiP Database seeks to fulfill three main objectives:

  1. Decrease the generation of waste containing hazardous substances by supporting the substitution of substances of concern in articles placed on the EU market
  2. Make information available to further improve waste treatment operations
  3. Allow authorities to monitor the use of substances of concern in articles and initiate appropriate actions over the whole lifecycle of articles, including at their waste stage

“How granular this is going to be is one of the big questions, and ECHA will make the information in the SCiP database available to waste operators, consumers and regulators at point of entry,” said AEM Director of Materials Management John Wagner. “What is known, however, is that you are supposed to have provided the information before your product is put on sale.”

Currently established milestones related to the development and launch of the SCiP database are as follows:

  • Autumn 2019 – Launch of a user test group and a stakeholder workshop at ECHA
  • Early 2020 – Launch of the prototype version of the database
  • July 2020 – Deadline for member states to transpose legal requirements into national law
  • Jan. 5, 2021 Notification duty (i.e. population of the database) kicks in for the industry

Many manufacturers are poised to be involved in the launch of the prototype version of the database, which is slated for early 2020. In the meantime, however, Wagner said companies that want to manufacture and sell products in the EU in 2021 and beyond need to be aware of the significance of the SCiP database.

“The bottom line is data collection needs to be considered a routine business practice moving forward,” he said. “There are so many regulations like this out there. And as with most things, Europe is leading the way. But the world is following Europe’s lead.”

According to LePard, it’s also critical for the industry to understand that all manufacturers – not just finished product manufacturers, but also component manufacturers as well – will need to report substances of concern.

Lessons Learned

In the late 1990’s, DXC Technology was heavily involved in the development of a database containing auto parts information and the chemicals that comprise those parts. And according to LePard, it has served as a blueprint of sorts for the ECHA’s formulation of its SCiP database.

“We have over 75 million product declarations in the database we’ve started, and that we maintain and operate,” said LePard. “We have been working very closely with the ECHA to help them understand what some of the opportunities and challenges are to maintaining the type of database and having this type of data collection. Those 75 million declarations we’ve collected are come from 180,000 different companies and over 510,000 people within those companies.”

A major lesson learned from the development of the auto parts database was that it is not sufficient for manufacturers to simply ask their suppliers if substances of concerns are contained in offerings.

“It’s not until you say ‘Tell me what’s in your product’ and provide evidence to support the reality of what you’re saying that you actually engage somebody who knows the answer,” said LePard. “This isn’t something you can put together overnight. In order to work your way down the supply chain from the finished article producer to the folks making the materials that know what chemicals are in the product, that takes some time. And the more complicated the product is, the more time it takes.”

The Bottom Line

As part of its import-export validations, the EU has said it will check whether manufacturers have provided believable information in the SCiP database as of January 2021. So, in a little more than a year from now, companies that wish to manufacture or sell their products in the EU must be prepared to provide accurate information on substances of concern contained in their product offerings – or face what would be a significant obstacle to market access.

“Because, and this is the bottom line, the people of Europe want safer products,” said LePard.

For more information on the SCiP Database and its impact on your organization, contact AEM’s John Wagner at jwagner@aem.org.

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