On 21 September, SEMI and a coalition of 40 industry organisations sent a letter to European Commission President Ursula von der Leyen calling for decisive action to solve implementation issues within the European Union Waste Framework Directive, specifically the Substances of Concern in Products (SCIP) database.
The signatories, who represent a very significant part of the European economy, are requesting urgent resolution of implementation issues for the SCIP database, which is designed to support the circular economy as defined in the European Green Deal. The database is required under Article 9.1 of the updated Waste Framework Directive.
In the letter, the signatories ask President von der Leyen to take immediate action to:
- Postpone the SCIP notification deadline of 5 January 2021 to at least one year after finalization of the database;
- Conduct a study on the usefulness, feasibility, proportionality and impact of the database;
- Instruct the European Chemicals Agency (ECHA) to adapt the SCIP database according to the outcome of the proposed study.
ECHA failed to complete development of the database by the January 2020 deadline required by the Waste Framework Directive, leaving companies insufficient time to develop, test and adapt their own systems to meet the January 2021 SCIP notification deadline.
Over the last two years, the signatories have repeatedly shared their serious concerns regarding the viability, proportionality and value of the SCIP database with the European Commission and the ECHA, yet those concerns remain unresolved.
Contrary to the EU Better Regulation principles that call for open and transparent decision making, Article 9.1 was added to the revised Waste Framework Directive 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 of driving a circular European economy.
Emir Demircan is director of Advocacy and Public Policy at SEMI Europe.