A coalition of 40 industry organizations, including Afera (European Association for the Self Adhesive Tape Industry), recently wrote a letter to European Commission President Ursula von der Leyen calling for decisive action to solve implementation issues within the EU Waste Framework Directive (WFD), specifically the Substances of Concern in Products (SCIP) database. Representing a significant part of the European economy, the signatories are requesting urgent resolution of implementation issues in a database designed to support the circular economy as expressed in the European Green Deal. This SCIP database is required by Article 9.1 of the updated Waste Framework Directive.

The signatories of the letter have asked von der Leyen to take immediate action to:

• Postpone the SCIP notification deadline of January 5, 2021, by at least 12 months after the database will be finalized
• 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 such study

ECHA reportedly 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. The signatories have serious concerns regarding the workability, proportionality, and value of the SCIP database, expressed repeatedly for the last two years; their concerns have reportedly not been resolved by the European Commission or ECHA.

Contrary to the EU Better Regulation principles, Article 9.1 was reportedly 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.

Additional information is available through Afera at www.afera.com.