Who is in scope?
Generally speaking, everybody in scope of the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation is in scope of the EU WFD. European Union manufacturers and importers of products into the EU will be responsible for submitting information into the SCIP database where SVHCs are present above 0.1 percent weight over weight (w/w) at the article level. Those importers often need to turn to their suppliers of articles to request information in order to fulfill their regulatory obligations. The following need to provide information to the SCIP database:
- EU producers and assemblers.
- EU importers.
- EU distributors of articles and other actors who place articles on the market.
- One exemption to this is if a distributor does not alter a product, they are exempt from submitting any information.
Retailers and other supply chain actors supplying articles directly to consumers are not obligated to submit information to European Chemicals Agency (ECHA). There is still contention about the ability of non-EU manufacturers appointing some kind of legal representative in the EU to cover the responsibilities of the importers.
What substances are in scope? How often will the substance list change?
Currently, the substances in scope for EU WFD matches the REACH Substances of Very High Concern (SVHC) Candidate List. Where an SVHC is identified on the REACH Candidate List above 0.1 percent w/w, the supplier of that product must report it to the SCIP database. This does not change if the article is then assembled into complex objects.
Raw substances or mixtures are not in scope for SCIP. Other EU regulations, such as EU REACH, handle substances and mixtures.
Products or components that do not contain SVHCs do not have to be reported.
Because the EU WFD references the REACH SVHC Candidate List, the list of substances will typically be updated every six months as shown by precedent.
Article content is current as of January 2020.