In our webinar “How to get ready for ECHA’s SCIP database“ we were excited to be able to give you an impression of the system-to-system solution that iPoint is working on to allow for a bulk upload of data to ECHA’s SCIP database and share our approaches of an easy analysis and reporting of data.
SCIP database and RoHS (2011/65/EU)
One interesting issue that came up in the Q&A session was whether there are requirements of a REACH notification along the supply chain (REACH Article 33(1)) and SCIP reporting (based on the Waste Framework Directive) for the RoHS-exempted lead.
In case you are operating under a valid RoHS exemption using lead in concentrations above 0.1%, this will mean that you will nonetheless have to notify your supply chain on the presence of an SVHC above 0.1% according to REACH Article 33(1) and also report the article (or complex object) to SCIP database from January 5th, 2021.
However, a remark has to be added to this general statement: RoHS and REACH differ in their reference point for the calculation of the concentration of a substance of concern (homogeneous material for RoHS vs. article for REACH), this might lead to differing calculation of concentrations of a substance of concern. For borderline cases this could mean differing obligations.