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LEGISLATION


IMDS Release 13.0 and the SCIP database


From January 2021, EU producers, assemblers, importers and distributors supplying articles containing ‘Substances of Very High Concern’ (SVHCs), listed on the REACH Candidate list with a concentration of 0.1% w/w or above are obliged to submit information to the SCIP database (“Substances of concern in articles or in complex products”). This database was established under the Waste Framework Directive (WFD) to inform recyclers about possible SVHCs in articles to allow them to take appropriate measures to protect the environment from SVHC substances during recycling.


REACH defines an article “as an object which during production is given a special shape, surface or design that determines its function to a greater degree than its chemical composition”. According to REACH, articles are for example clothing, flooring, furniture, jewellery, newspapers and plastic packaging, certainly not the description of a lubricant. At first glance, only packaging (e.g.: containers and drums) and lubricant test equipment (e.g.: pH test strips) are relevant subjects of the SCIP database. But what about lubricants in articles, for example, the engine oil in a car? Are lubricants subject to this directive? Do lube blenders have to submit information on the SVHCs in their lubricants to the SCIP database?


REACH insists that suppliers of mixtures are obliged to submit information on identified SVHCs in the Safety Data Sheet (SDS). Thus, an article manufacturer who buys lubricants containing ingredients identified as SVHC gets an SDS and could submit this information about his article to the SCIP database. This seems logical since the lube blender doesn’t know where his lube product will end up; furthermore, lubes do not fulfil the ECHA (European Chemicals Agency) criteria of an article as described above.


In the case of the automotive industry the International Material Data Systems (IMDS) database already exists where all materials used for automobile manufacturing, including any relevant information about substances used in cars, must be listed. This sounds like “double


Stephan Baumgartel, Manager, VSI


work” for SVHCs in cars which have to be declared both in SCIP and IMDS. However, with the planned enhancements for the latest IMDS Release 13.0, due for May 2021, IMDS will support the creation and submission of SCIP dossiers based on existing MDS information within IMDS whenever possible.


More information on ‘Adding new required attributes and interface to transfer MDSs one by one to SCIP’, including fields for the newly created components within IMDS Release 13.0, will be eagerly reviewed following its publication, and will certainly be the subject of further discussion within the UEIL working groups.


LINK www.ueil.org/about-us/structure/ hse-committee/


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