New database places considerable burden on medium-sized companies
From January 2021, almost every manufacturer of machinery and equipment in Europe will have to enter information on chemical substances used into the database (SCIP) of the European Chemicals Agency (ECHA).
According to a current VDMA survey, companies will need an average of 20 man-years for the complete first filling - an unjustifiable effort! The reason for this is the EU Waste Framework Directive, which will be amended in 2018. This stipulates that from January 2021, every supplier of articles containing a certain level of substances of very high concern (SVHC) must provide the European Chemicals Agency (ECHA) with comprehensive information. The SCIP database developed for this purpose goes even further, as additional information must also be provided by the companies for each product variant. The aim is to use this information to advance the recycling economy.
"With the European SCIP database a huge bureaucratic wave is rolling towards the manufacturers of complex products. It remains to be seen whether the goal of improving the recyclability of products and the materials they contain will be achieved in terms of the circular economy.
National implementation of European requirements
At present, the German legislator is dealing with the national implementation of the European project and provides for this in the area of waste legislation in the Recycling Management Act. A hearing on this is to take place in the Bundestag on July 1.
"With the European SCIP database, a huge bureaucratic wave is rolling towards the manufacturers of complex products. It remains to be seen whether the goal of improving the recyclability of products and the materials they contain will be achieved in terms of the circular economy. After all, it is not only the manufacturers of products, components or complete machines who have to struggle with the flood of data, but ultimately also the recyclers when they search for the appropriate database entries for machines produced 20 years ago and, if necessary, converted several times", warns VDMA General Manager Thilo Brodtmann.
Problem Know-how protection
Especially small and medium-sized companies are faced with the enormous task of having to retrieve all information that goes beyond the legal framework for each individual part in their products along the supply chain. "With thousands of individual parts in machines and plants, this is a disproportionately large bureaucratic effort", emphasizes Brodtmann. Another problem is the protection of know-how. Companies are concerned about disclosing their supply chains and know-how. In addition, six months before the submission deadline, only a slimmed-down prototype version of the database is available for testing purposes. "The full SCIP database is expected to be available with a delay of ten months in October 2020. This means that the period for transmitting all information has been reduced from originally one year to a few weeks", explains Brodtmann, "We are therefore calling for an extension of one year from the completion of the database, the possibility of gradual data entry, and the practical possibility of grouping database entries. Here the possibility would arise concretely of relieving enterprises straight in the time after Corona by bureaucracy dismantling. Germany must also be involved in the design of the database: the national implementation in the Chemicals Act must not go beyond what has been decided at European level", demands the VDMA General Manager.