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In the context of the Waste Framework Directive, ECHA will establish the Substance of Concern in Products (SCIP) database in 2021. Suppliers of articles need to provide information to this database on those articles which contain Candidate List substances in a concentration above 0.1% w/w as from January 5, 2021.

SAFEGUARDS | Consumer ProductsNO. 163/19

 Scientists in Lab

Starting January 5, 2021, companies placing articles on the EU market need to provide information to the SCIP database on those articles which contain Candidate List substances in a concentration above 0.1% w/w. Duty holders are EU producers, assemblers, importers and distributors and other actors who place articles on the EU market.

Retailers and other supply chain actors supplying articles directly to consumers do not need to provide information to the SCIP database.

Background on SVHC Substances and the Candidate List

SVHC is a term used in the context of the EU REACH regulation. Substances with certain hazard properties may be identified as Substances of Very High Concern (SVHC): CMR (carcinogenic, mutagenic or toxic for reproduction), PBT/vPvT (persistent, bioaccumulative/very persistent and very bioaccumulative) or substances that cause an equivalent level of concern as CMR or PBT/vPvB substances; e.g. endocrine disruption.

SVHCs are added to the Candidate List published by the European Chemical Agency (ECHA) following a particular decision process. This list is called the “Candidate List” because substances on the list may be moved to the Authorization List. There are notification and communication obligations under REACH for suppliers of articles containing Candidate List substances.

REACH: Notification and Communication Compared with SCIP Duty

It is however important to note that the SCIP is established in the context of the Waste Framework Directive, not the REACH regulation. Therefore, the fact that actors supplying directly to consumers are exempt from the duty with regards to SCIP does not affect the existing communication and notification obligations under the REACH regulation.  Suppliers of articles that contain Candidate List substances in a concentration above 0.1% w/w need to communicate to the recipient of the article even when they have no duty to provide information to the SCIP database.

Detailed Information Requirements

Details on information requirements were published in September 2019. The following information is required:

  • Administrative contact details (company information)
  • Technical details
    • Information on the article as such or the complex object
      • Identifiers (name, brand, model, identifier (i.e. EAN), production in EU (yes/no))
      • Picture
      • Characteristics (dimensions, weight, color…)
      • Instructions (safe use, disassembling)
      • For complex object components only: linked articles
    • Information on the substance
      • Candidate List version
      • Candidate List substance (name, EC and CAS number)
      • Concentration range (select as appropriate)

The database will be set up by ECHA (the European Chemical Agency). National authorities have responsibility for the enforcement of these new obligations.

 

Example of technical information provided for an O-ring: (source: ECHA, September 2019)

For more information, listen to the recording of the ECHA workshop on the SCIP database (November 12, 2019).

 

 References:

SVHC may be introduced into various consumer products due to the complexities of both the supply chain and production process. Identifying high risk products or materials or having a test strategy can also be a smart way to ensure compliance and save costs.  If you would like to learn more about how SGS can support your REACH compliance activities please contact us at reach@sgs.com or visit www.sgs.com/reach

For enquiries, please contact:

Adeline Maijala
Quality and Development Lead - Certification Services
Tel: 
+358 9 6963 229

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