Background to the SCIP Database
The Substances of Concern In articles as such or in complex objects (products) database — SCIP — was introduced in 2021. It required companies producing, importing, or distributing articles containing SVHCs above 0.1% weight-by-weight to submit detailed notifications to the European Chemicals Agency (ECHA).
Its stated aim was to support waste operators and recyclers in managing hazardous substances more safely. However, the database has faced criticism over limited practical use, especially for business-to-business (B2B) transactions and space industry applications, as well as for duplicating obligations already set under REACH Article 33(1).
Key Drivers Behind Repeal
Stakeholder feedback highlighted several issues:
- Low usage by waste operators and consumers
- Complexity of data submissions
- Overlap with existing REACH obligations
Furthermore, the SCIP database was added to the Waste Framework Directive through a legislative amendment, without prior impact assessment.
The Commission argues that upcoming regulatory tools — particularly the digital product passport under the Ecodesign for Sustainable Products Regulation (ESPR) and the Common Data Platform on Chemicals under the One Substance, One Assessment initiative — will provide better and more accessible chemical information by 2030.
Financial and Operational Impact
Industry estimates suggest:
- Around 10,000 companies may be submitting data annually
- Each submission takes an average 30 minutes
- Average direct cost: €30 per submission
Larger firms experience some economies of scale, while smaller firms face disproportionately high upfront IT and compliance costs ranging from €1,000 to €250,000.
Abolishing the SCIP obligation could reduce administrative burden by €225 million per year, with additional cost savings for ECHA, which currently bears millions in annual maintenance costs.
Regulatory Safeguards and Alternatives
Despite the repeal, chemical safety goals will remain intact:
- REACH Article 33(1) will still mandate downstream communication on SVHCs.
- The digital product passport (starting 2027) and ESPR labelling will consolidate product chemical data access.
- The Common Data Platform on Chemicals aims to centralise hazard and exposure data for all substances of concern by 2030.
These parallel efforts should maintain transparency for recyclers, consumers, and authorities.