In most EU countries, a new EU SCIP register came into force on 1 January 2022, which includes products containing hazardous substances. The introduction of this register has not been properly publicized and it is worth getting acquainted with this regulation due to the high financial penalties provided for in it.
The three main goals of the SCIP database:
- Reduce the production of waste containing hazardous substances by helping to replace hazardous substances in articles placed on the EU market;
- Sharing information to help further improve waste treatment operations;
- Enable authorities to monitor the use of hazardous substances in articles and initiate appropriate actions at all stages of the life cycle of articles, including the waste stage.
The list of substances, which are covered by new register, is long and it grows more and more. It is worth noting that the notification to the SCIP will apply to products containing such substances (e.g. a cars or laptops). Information under SCIP will be provided by:
- EU entities producing and assembling products – as a consequence, for example, manufacturers of electronics and cars will have to register in the register;
- EU importers;
- EU distributors of articles (for example electronics stores) and other actors in the supply chain placing them on the market, excluding a retailer who sells directly to an individuals.
It is worth emphasizing here that the submission of a notification by the supplier does not release the next entity in the supply chain from liability. As a consequence, if the supplier has submitted a notification to SCIP and another entity in the chain has failed to do so, the authority may impose a penalty on him. Referring to the reporting of another entity in this situation will not help. It is worth being careful in this regard, because the penalties range from tens of thousands of euros per product that has not been submitted to the database to even several million euros for failure to register (depending on the law of EU member state).
In addition, entities required to register will have to re-submit notifications in case when the products change, their composition, construction, etc. Thus, registration with SCIP is not a one-time registration, but one that must be carefully monitored.
Authors:
Krzysztof Winski, Director, +48 519 506 434, krzysztof.winski@pwc.com
Łukasz Pamuła, Manager, +48 519 504 779, lukasz.pamula@pwc.com
Wiktoria Wyszyńska, Consultant, +48 519 506 233, wiktoria.wyszynska@pwc.com
Image Source: http://unsplash.com
Michaela Merz 