by Ancuta Rusu, PhD
Pushing towards a Circular Economy where the generation of waste is minimized, in particular waste containing hazardous substances, ECHA has set up a new reporting obligation based on the revised Waste Framework Directive. It’s aim is to increase awareness of hazardous substances in waste to better equip waste operators, consumers and authorities.
For waste operators, this information can help ensure waste that contains hazardous substances is being properly processed prior to potential reuse or recycling. For consumers, this information may aid in better choices when buying, using, and disposing of products, and for authorities, the database will allow better monitoring of SVHCs in articles and may assist in future regulatory actions.
From 5 January 2021 onwards, EU producers and assemblers, EU importers, and EU distributors of articles as well as any other actor who places articles on the market, should provide information to ECHA on the safe use of such articles that contain SVHCs from the Candidate List in a concentration above 0.1% w/w. The legal obligation also covers articles imported into the EU, including imports from internet sales.
The dossiers will be submitted either online through the ECHA Submission portal or through a system-to-system (S2S) transfer from the company’s own system to the ECHA Submission portal. The submissions can be prepared in IUCLID (online or offline) or using an IUCLID-compatible dedicated format for SCIP submissions in the company’s own system.
The information required to be submitted includes:
- Company data
- Article data (identification of the article, description of the article)
- Candidate List substance data (name, concentration range and location of the substance in the article)
- Safe use information (to facilitate its management when it becomes waste)
Recommended Action Items
- Check your product portfolio and the Candidate List to see if obligations apply
- Check for SVHCs regularly, as new substances are usually added to the Candidate List twice a year
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- Waste Framework Directive
- Circular Economy
- Candidate List
- European Union