In an article published on October 11, 2018, by regulatory news provider Chemical Watch, editor Leigh Stringer informed about criticisms raised by the industry groups regarding the database of substances of very high concern (SVHCs) in products that the European Chemicals Agency (ECHA) plans to launch in late 2019 (FPF reported). The ECHA’s proposal for the realization of this database followed the publication of the revised waste legislation (FPF reported), which newly requires companies to notify ECHA of SVHCs’ presence in articles (FPF reported). The ECHA-managed database is envisaged to “contain information submitted by companies producing, importing or supplying articles that contain candidate list substances,” which should be provided for articles to be placed on the market after January 5, 2021. A consultation on the ECHA’s proposal for this database closed on October 9, 2018.

Stringer informed that the waste Directive “requires a company, at a minimum, to declare the presence and name of any SVHCs in articles.” However, the “proposals for the database,” published by ECHA, include “unique identifiers for each article and more detailed information such as the concentration limits of SVHCs in the articles.” In response to this, Steve George, chair of the REACH and chemicals management working group of the European aerospace and defense industries association (ASD), commented that such “article-centric approach” will result in “widespread non-compliance across all industry.” Timo Unger, environmental manager at Hyundai, said that the logistics behind such reporting would require companies to build new information management systems that could cost “billions of euros.”

The European recycling industry association (EuRIC), on the contrary, “supports the principle behind the database” and “welcomes the idea” of centralized information, improved traceability of substances in waste streams, and better protection of workers in recycling facilities. The position paper by EuRIC explained that “waste treatment officers will only benefit if the data can easily be accessed by product and sub-product categories.” It also expressed concerns that “the database will not solve the issue of legacy substances in articles,” because the reporting requirement does not apply to articles which are “already placed on the market.

On October 22-23, 2018, ECHA will host a workshop on the Waste Framework Directive database in Helsinki, Finland, “targeted at Member State authorities and stakeholders.” According to ECHA, “the primary users of the database are the waste treatment operators and consumers.” The workshop agenda includes “presentation of draft scenario and outcome of call for input,” along with “breakout discussions on workability, assumptions and main open questions.” The plenary sessions will be web-streamed live.

Read more

Leigh Stringer (October 11, 2018). “ECHA SVHC database will ‘add little benefit to waste operators.’Chemical Watch

Timo Unger (September 2018). “Beware the law of unintended consequences.Chemical Watch

EuRIC (September 18, 2018). “Position of the European Recycling Industries’ Confederation. ECHA Database on Candidate List substances.(pdf)

ECHA (2018). “Workshop on Waste Framework Directive database.


ECHA (2018). “Draft scenario for the database on articles containing Candidate List substances.(pdf)

ECHA (2018). “Technical supporting document to the Draft scenario for the database on articles containing Candidate List substances.(pdf)