FEAD position on the discontinuation of SCIP database under the Environmental Omnibus
FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the European Commission’s efforts to reduce administrative burden and simplify environmental legislation. However, simplification should not undermine the availability of essential information required for the functioning of the circular economy. Effective waste management and high-quality recycling depend on access to reliable data on the composition of products, in particular the presence of substances of very high concern (SVHCs).
A needed tool for transparency on substances of concerns
FEAD recognises the limitations of the current SCIP system. The database is overly complex, difficult to use in practice and not sufficiently adapted to the operational needs of waste management companies. Its current structure does not allow efficient use at industrial scale.
Nevertheless, FEAD does not support the complete deletion of SCIP.
Despite its shortcomings, SCIP remains one of the only EU-wide tools providing structured information on the presence of SVHCs in products at end-of-life. This information is relevant to assess recyclability, ensure appropriate treatment of waste and support safe recycling operations.
The removal of SCIP without a functional and equivalent alternative risks reducing transparency on substances of concern in waste streams and may negatively impact recycling processes.
Improving SCIP database rather than deleting it
FEAD considers that the appropriate approach is not to remove SCIP, but to simplify and improve it. Priority should be given to:
- Reducing reporting complexity
- Improving data accessibility and usability
- Aligning the system with the needs of waste operators.
Information requirements should be proportionate and ensure that data can be effectively used in waste management operations.
Alignment with the Digital Product Passport
In order to address these shortcomings, the SCIP database should not be discontinued outright but rather improved and integrated with the new Digital Product Passport, maintaining the responsibility of the producers and allowing greater transparency.
This integration should avoid duplication, ensure compatibility, and create a system designed for day-to-day use within the waste management sector. It must be efficient, scalable, and deployable at industrial level, thereby enhancing transparency across the entire value chain with regard to materials and potential contaminants.
A complete phase-out of the SCIP database without a functional alternative for communicating the presence of substances of concern in end-of-life articles would risk undermining certain recycling operations and bring discontinuity to the future ambitions for the Ciruclar Economy.
FEAD amendments to the Commission’s proposal
Recital 5
The database established pursuant to Article 9(2) of Directive 2008/98/EC containing the information referred to in Article 33(1) of Regulation (EC) No 1907/2006 of the European Parliament and of the Council13 was devised to enhance transparency and provide comprehensive access to information on hazardous substances in products. It is acknowledged that the complexity of the notification process imposes significant burden on industry stakeholders, leading to disproportionally high costs, especially regarding necessary IT investments. Coupled with a low rate of access by potential users and the limited usability of the information due to its current structure, alongside low compliance and enforcement rates, it is estimated that the database in its current form is not fulfilling its intended objectives. Hence, the obligation for suppliers to submit data to the database should not be continued. Data that has already been reported should continue to be maintained by the European Chemicals Agency. The obligation for suppliers to submit data to the database should be maintained until an alternative system ensuring at least an equivalent level of information on substances of very high concern in articles is fully operational and accessible to waste operators and other relevant stakeholders. The phase-out of the SCIP database should be conditional upon the deployment of such an alternative system.
Article 1.2
2. Article 9 is amended as follows:
(a) The following point is inserted at the end of paragraph 1(i) is amended as follows:
(i) point (i) is replaced by the following:
‘(i) promote the reduction of the content of hazardous substances in materials and products, without prejudice to harmonised legal requirements concerning those materials and products laid down at Union level
The European Commission and European Chemicals Agency shall ensure that data submitted pursuant to this paragraph is progressively integrated into interoperable digital systems, including the Digital Product Passport, ensuring accessibility and usability for waste operators. Economic operators shall not be subject to a discontinuity in obligations regarding the communication of substances of concern. Transitional measures shall ensure continuity between existing and future digital systems.
(ii) the following point (ia) is inserted:
‘(ia) ensure that any supplier of an article as defined in Article 3, point 33 of Regulation (EC) No 1907/2006 of the European Parliament and of the Council* provides the information pursuant to Article 33(1) of that Regulation to the European Chemicals Agency from 5 January 2021 until [date of entry into force of this Directive];’
(b) The following point is inserted at the end of paragraph 2 is replaced by the following:
‘2. The European Chemicals Agency shall maintain the data submitted to it pursuant to paragraph 1, point (ia).’
The Commission shall adopt Delegated Acts to simplify the information requirements and reporting formats for substances of concern, reducing administrative burden while maintaining traceability, and to redesign the SCIP database so it is operationally usable by waste management operators, including through simplified formats, aggregation where appropriate, and compatibility with industrial processes.
FEAD, the European Waste Management Association, represents the entire waste management value chain, from collection and sorting to recycling, energy recovery, and final disposal. It brings together the private waste and resource management industry across Europe through its 21 national member associations and associate members, which collectively represent over 3,000 companies. Together, the sector provides more than 500,000 local jobs and fuels €5 billion in investments into the economy every year. For more information, please contact: info@fead.be