Accelerating the substitution of hazardous chemicals and transition towards a safer circular economy
It may seem clear that a recycled product should be as safe as a virgin product. However, in practice it is often difficult to fully exclude the presence of hazardous substances in the recycled product due to the mixed waste streams that serve as raw material.
Substances of very high concern
Chemical substances that meet certain REACH criteria– such as being carcinogenic, toxic for reproduction, or persistent in the environment- may be proposed as SVHC (substance of very high concern). Listing of a substance as an SVHC by the European Chemicals Agency (ECHA) is the first step in the procedure for authorisation or restriction of use of a chemical.
Although these high concern substances can be considered unwanted due to their hazardous nature nowadays, they are used (and in the past in large quantities) due to their flame retardant, stabilizing, or other functional properties in plastics, furniture, building materials, and electronics.
Currently manufacturers or suppliers to comply with REACH, must identify and monitor SVHC substances in their products. In addition to identifying potential SVHC substances, companies must check whether applied substances appear on the REACH list of restrictions (Annex XVII) and / or the REACH authorization list (Annex XIV).
To avoid SVHC substances from ending up in toys, clothes or food packaging made from recycled feedstock it is important that these chemicals can be tracked from manufacturing to waste. This way, waste processors and secondary manufactures (recyclers) know if a waste product contains one or more of these substances and how to safely extract them from the waste streams.
Bjorn Hansen, ECHA’s Executive Director says: “Tracking harmful chemicals is the key for moving towards a more sustainable circular economy. All materials are made of chemicals and we need to make sure we know which products contain harmful chemicals before they are recycled. Our upcoming database will help us to make products safer.”
The SCIP database
This upcoming database is ECHA`s SCIP database. The new SCIP database will contain information on Substances of Concern in articles, as such or In complex objects (Products). The aim is to promote the substitution of hazardous chemicals and transition towards a safer circular economy. This way it is ensured that the information is available throughout the whole lifecycle of products and materials, including at the waste stage.
Who needs to submit information
An SVHC on the Candidate List must be present in an article in a concentration above 0.1 % to trigger the submission requirement.
The following suppliers of articles will need to submit information to the SCIP database:
- EU producers and assemblers;
- EU importers; and
- EU distributors of articles and other actors who place articles on the market.
Retailers and other actors supplying articles directly to consumers do not need to submit information to ECHA.
Producers and distributors of articles produced outside of the EU do not have direct obligations under the Waste Framework Directive. However, they should support their EU customers (importers) by providing them with the necessary information on SVHCs in articles.
Notification and Communication of SVHC under REACH regulation vs Obligations SCIP database
Although the database is put in place by ECHA, the SCIP database is established under the Waste Framework directive not REACH. Therefore, the existing communication and notification obligations on SVHC substances in articles under REACH are not replaced by the introduction of the SCIP database.
What can we do to Help
To fulfil the notification obligations under REACH and the SCIP we can support you in the following steps:
- Assess your products
- Implement a system for identifying and tracking SVHC substances in your articles
- Collect information (e.g. REACH certificates) from your suppliers
- Assess if the concentration of SVHC reaches the 0.1 % threshold
- Create a SCIP notification dossier (a IUCLID template will be available for this)
- Submit your notification dossier.
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What is an article
Under REACH an article is an object which during production is given a special shape, surface or design which determines its function to a greater degree than its chemical composition does. Examples of articles are plastic packaging or cloths
There are also Complex objects which may be made of several individual articles. This can be something as complex an e-bike consisting of hundreds of different articles (frame, battery, electronics, tyres etc).
The SCIP Communication obligations on SVHC substances in articles also apply to every article incorporated in a complex object.