From January 5, 2021, suppliers of articles and complex products must have entered the substances of very high concern (SVHC) they contain in the EU SCIP database. This is provided for in the amended EU Waste Framework Directive, which is currently being transposed into the German Closed Substance Cycle and Waste Management Act. As SVHCs such as lead are contained in many steel or aluminum components, this affects a very large number of products and companies, warn the experts at Dekra.
SCIP stands for Substances of concern in articles, as such or in complex objects (products). The database was created to give waste management companies access to SVHC information in line with REACh Art. 33. However, the scope of the information queried in the database mask is much greater than specified in Art. 33. The new obligation affects all suppliers of products that exceed the limit value for SVHC of 0.1% in at least one "article" (component). This can be, for example, a lead-containing alloy in components or plasticizers, flame retardants or UV stabilizers in plastic parts.
The SVHC concentration can be determined using information from the supply chain, laboratory analyses or knowledge of material-specific SVHC:
For example, semi-finished products made of free-cutting steel or aluminum for machining, which therefore contain lead. The notification must be generated in a special XML format. This is possible via the IUCLID tool of the Chemicals Agency ECHA. In addition, some specialized service providers offer solutions for direct data transmission from the supplier's databases.
