Please observe timely the notification obligation for articles containing SVHC as of 5 January 2021

As of 5 January 2021, notification of articles containing SVHCs is mandatory according to the amendment to EU Directive 2018/851. SVHC stands for “Substances of Very High Concern”. All articles containing more than 0.1% by mass of SVHC substances are subject to compulsory notification. In particular, articles such as CdTe photovoltaic modules are subject to notification due to their product characteristics. Many other electrical and electronic equipment may also be affected, as heavy metal compounds and flame retardants are also included in the SVHC list. Recommendation: Please make timely preparations for such mandatory notification so that you or your suppliers have sufficient lead time until 5 January 2021.

The European Chemicals Agency (ECHA) has published the first prototype of the Substances of Concern in Products (SCIP) database.

As of 5 January 2021, notification of articles containing SVHCs is mandatory according to the amendment to EU Directive 2018/851. SVHC stands for “Substances of Very High Concern”. This must be implemented into national law by July 2020. It allows the appointment of an authorised representative to assume the associated obligations of manufacturer responsibility. ECHA plans to publish the first version of the SCIP as of October 2020.

The duty of notification applies to every supplier, manufacturer, importer and even assembler. Retailers and others in the supply chain who supply directly to the consumer are exempted from this. The importer must notify in the case of non-EU producers.

All articles containing more than 0.1% by mass of SVHC substances are subject to compulsory notification. In particular, articles such as CdTe photovoltaic modules are subject to notification due to their product characteristics. Many other electrical and electronic equipment may also be affected, as heavy metal compounds and flame retardants are also included in the SVHC list.

The IUCLID6 portal is used for the procedure of submitting notifications to the ECHA submission portal.

Objectives of the database: The database is intended to help waste management companies identify SVHC substances and to separate them from other waste. The transparency of the database provides the consumer with information on the use and disposal of the articles in question.

The list of candidates of SVHC substances can be found at: https://echa.europa.eu/de/candidate-list-table

Further information about SCIP in English can be found at: https://echa.europa.eu/de/scip-database

Recommendation: Please make timely preparations for such mandatory notification so that you or your suppliers have sufficient lead time until 5 January 2021. Boris Berndt at TMK Retail Service & Consulting GmbH will be pleased to answer your questions; please phone +49/40/54090410-8 or send an e-mail message to info@retailconsult.info.