Environment: Orgalim calls for an impact assessment and a delay of implementation of ECHA SCIP database

Published: 30 June 2020

Policies & Issues: Environment

The upcoming Waste Framework Directive SCIP database deadline of 5 January 2021 should be delayed by at least one year to allow the European Commission to undertake an impact assessment of the database to ensure that its implementation will be workable, proportionate and will contribute to a circular economy.

 

Europe’s technology industries, represented by Orgalim, are major downstream users and article manufacturers under the REACH Regulation 1907/2006/EC.

Our industries are fully committed to reducing the content of hazardous substances in their products to support a more circular economy and achieve sustainability goals. A meaningful exchange of information between partners in the value chain focusing on Substances of Very High Concern will improve recycling and therefore contribute to a circular economy. When looking at legislation to achieve these goals, our industries believe that any proposal should be evaluated on the basis of its demonstrable improvements for the environment.

One example of new legal requirements is the Waste Framework Directive (WFD) 2018/851 and its Article 9. This sets out a requirement for the European Chemicals Agency (ECHA) to establish and maintain a database for the submission of information by suppliers of an article pursuant to Article 33(1) of REACH Regulation. Our industry is strongly affected by this new requirement, and Orgalim is actively contributing to the development of this SCIP database - the database for information on Substances of Concern In articles as such or in complex objects (Products) established under WFD - by providing regular feedback and input to the European Commission and ECHA to help them improve the database. Since February 2018, we have on several occasions expressed our serious concerns regarding the workability, proportionality and added value of this database.

On 23 April 2020 Orgalim sent a letter to President von der Leyen concerning the Commission’s work in 2020 in light of COVID-19 in which we called on the Commission to delay by at least one year the upcoming Waste Framework Directive SCIP database deadline of 5 January 2021: for suppliers of articles to provide the information pursuant to Article 33(1) of REACH Regulation - to allow the Commission to do an impact assessment of the database, and for all the reasons explained in this position paper.

To read our recommendations in full, please download the position above.

Authors

Mittelham
Stéphanie Mittelham
Manager - Environment

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