Environmental Omnibus: Joint industry statement on SCIP database

MedTech Europe, alongside other associations, are calling on EU policymakers to confirm the repeal of the Substances of Concern in articles as such or in complex objects (Products) (SCIP) database, as proposed by the European Commission under the Environmental Omnibus.

While transparency on substances of very high concern remains essential, five years of implementation have shown that SCIP places a significant administrative burden on companies without delivering meaningful benefits for recyclers and waste operators. The database duplicates information that suppliers are already required to provide under REACH Article 33(1), while creating costly reporting obligations that are particularly challenging for SMEs and manufacturers of complex products with multiple components and supply-chain variations*.

MedTech Europe, alongside the co-signatories, calls for:

• Confirmation of the repeal of the SCIP database, as proposed under the Environmental Omnibus and supported in the ENVI Committee draft report, removing a costly and ineffective reporting layer that has not achieved its intended objective.
• Preservation of REACH Article 33(1) as the primary mechanism for communicating information on Candidate List substances, ensuring that suppliers continue to provide customers with information on substances of very high concern without duplicative reporting requirements.
• Future substance information requirements to build on existing supply-chain obligations rather than creating new reporting systems, avoiding unnecessary administrative burdens, particularly for SMEs and companies producing complex products.

Repealing SCIP would provide immediate regulatory simplification while maintaining the flow of information on substances of concern throughout the value chain. It would also support a more proportionate and effective approach to chemicals reporting, allowing resources to be focused on measures that deliver real environmental and circular economy benefits.

Read our full joint statement via the link below.

*Source: European Chemicals Agency: First ex-post Evaluation of SCIP (May 2022)