On Monday 21st September, a coalition of 40 industry organisations wrote a letter to EuropeanCommission President Ursula von der Leyen calling for decisive action to solve implementation issueswithin the EU Waste Framework Directive (WFD), specifically the Substances of Concern in Products (SCIP) database.

The signatories representing a very significant part of the European Economy request urgent resolution of implementation issues in a database designed to support the circular economy as expressed in theEuropean Green Deal. This “SCIP” database is required by Article 9.1 of the updated Waste Framework Directive.

The signatories of this letter ask President von der Leyen to take immediate action to:

1. Postpone the SCIP notification deadline of 5th January 2021 by at least 12 months after the database will be finalised;

2. Conduct a study on the usefulness, feasibility, proportionality and impact of the database, and;

3. Instruct the European Chemicals Agency (ECHA) to adapt the SCIP database according to the outcome of such study.

ECHA failed to finalize the database development to the required timescale of January 2020, preventing companies from developing, testing and adapting their own systems to meet the January 2021 notification deadline.

Signatories have serious concerns regarding the workability, proportionality and value of the SCIP database, expressed repeatedly for the last two years, but their concerns have not been resolved by the European Commission, nor by ECHA.

Contrary to the EU Better Regulation principles, Article 9.1 was added to the revised WFD during the final stage of the co-decision process without any prior stakeholder consultation or impact assessment. A proper impact study should help shape the way forward to deliver on the EU ambition for a circular European Economy.

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