Environment: 40 industry organisations call for urgent actions to postpone the legal obligations to the ECHA SCIP database

Published: 21 September 2020

Policies & Issues: Environment

On Monday 21st September, a coalition of 40 industry organisations wrote a letter to European Commission President Ursula von der Leyen calling for decisive action to solve implementation issues within the EU Waste Framework Directive (WFD), specifically the Substances of Concern in Products (SCIP) database.

The signatories representing a very significant part of the European Economy request urgent resolution of implementation issues in a database designed to support the circular economy as expressed in the European Green Deal. This “SCIP” database is required by Article 9.1 of the updated Waste Framework Directive.

The signatories of this letter ask President von der Leyen to take immediate action to:

  1. Postpone the SCIP notification deadline of 5th January 2021 by at least 12 months after the database will be finalised;

  2. Conduct a study on the usefulness, feasibility, proportionality and impact of the database, and;

  3. Instruct the European Chemicals Agency (ECHA) to adapt the SCIP database according to the outcome of such study.

ECHA failed to finalize the database development to the required timescale of January 2020, preventing companies from developing, testing and adapting their own systems to meet the January 2021 notification deadline.

Signatories have serious concerns regarding the workability, proportionality and value of the SCIP database, expressed repeatedly for the last two years, but their concerns have not been resolved by the European Commission, nor by ECHA.

Contrary to the EU Better Regulation principles, Article 9.1 was added to the revised WFD during the final stage of the co-decision process without any prior stakeholder consultation or impact assessment. A proper impact study should help shape the way forward to deliver on the EU ambition for a circular European Economy.

Authors

Mittelham
Stéphanie Mittelham
Manager - Energy and Environment

Related Position Papers

Environment: Orgalim comments on the draft French Decree on the minimum proportion of reused packaging [28 October 2021]

Environment: Financing key enablers of the green transition: Orgalim position on the EU taxonomy for sustainable activities [6 October 2021]

Environment: Orgalim response to the consultation by the Platform on Sustainable Finance on EU taxonomy [5 October 2021]

Environment: Joint statement on the need for a transition period for the implementation of the Batteries Regulation [28 July 2021]

Environment: Orgalim input to the European Commission consultation on the Revision of the Urban Waste Water Treatment Directive [20 July 2021]

Environment: Orgalim position on the Sustainable Products Initiative [8 June 2021]

Environment: Orgalim position on draft reporting rules for companies under the EU Taxonomy Regulation [2 June 2021]

Environment: Orgalim position on the cross-cutting aspects of the Ecodesign and Energy Labelling Working Plan 2020-2024 [2 June 2021]

Environment: Orgalim comments on the REACH revision roadmap [1 June 2021]