The European Commission and the European Chemicals Agency (ECHA) reject a proposal from the industry which aims at simplifying its implementation without changing the targets 


The Industry Task Force working on Non Road Mobile Machinery (ITF NRMM), represented by European associations such as CEMA, CECE, EGMF, EUnited and FEM and supported by Euromot, prepared a document intended to propose alternatives for the implementation of the last amendment of the Waste Framework Directive, which requests each company that produces, imports or supplies articles containing dangerous substances to register these products on a database from 5 January 2021.

The database is called SCIP (Substances of Concern In articles as such or in complex objects (Products)) database.  For each product registered, it must contain the list of dangerous substances, officially called Substances of Very High Concern (SVHCs), as listed in the Candidate List regularly updated under REACH.

The goal of the SCIP database is to:

  • Decrease the generation of waste containing hazardous substances
  • Make information available to further improve waste treatment operations
  • Allow authorities to monitor the use of SVHC

ITF NRMM proposed a simplification for the registration of the product by using notification at machine model level and referencing systems already recorded in his documents, which was intended to be discussed during the WASTE and Competent Authorities for Reach and CLP (CARACAL) expert groups meeting planned on 9 July 2020. You can read it here

This proposal highlights in particular the unavailability of the SCIP database, which should have been finalized by beginning of 2020 and the lack of impact assessment to evaluate the associated costs and benefits.

The European Commission and ECHA maintain their approach and the timeline; while ECHA does not recommend the notification at machine model level.