SCIP database is open, but concerns & shortcomings remain

Considering ECHA’s delay in making the database available, companies will have only two months to submit the information, a much shorter period than the official 12 months foreseen in the European Waste Framework Directive (WFD). In addition to this delay, ECHA has overstepped its mandate fixed in the WFD, extending the database obligations beyond the legal requirements of REACH article 33, thus making manufacturers’ compliance even more challenging, burdensome and time-consuming.

A wide coalition of European industry organisations raised concerns regarding the SCIP in many occasions and recently addressed them in a joint industry letter to Commission President von der Leyen. In their dismissive and partly incorrect reply letter, the Commission stressed that the obligations will go ahead as planned and invites industry to contact ECHA.

Nonetheless, a delegation from the industry coalition will meet DG Environment in the coming weeks to discuss the legal situation, in addition to the many implementation points that are being overlooked by ECHA.

Central to these practical challenges is the IT readiness of the online platform. Indeed, in a recent workshop, ECHA asked companies intending to submit large amounts of data to call ECHA’s IT department beforehand, to prevent the database from crashing. This confirms industry’s doubts about the tragic underestimation of the size of this platform and of the task at hand by ECHA and the whole Commission. According to CECE, this also shows the fundamental role of impact assessments and consultations, when creating new regulatory obligations and tasking an EU agency with its implementation.

In addition to these actions, the same industry coalition addressed these concerns to the German Presidency of the Council, where it requests for support and consideration of those issues.

For more information on this topic and to join the relevant CECE group (if you are a member) please contact info@cece.eu.