In this article, Michael Kirschner discusses the regulatory landscape, including a close look at the European Chemicals Agency’s Substances of Concern in Products (SCIP) database.
Good Riddance SCIP? The European Commission (EC) is committed to reducing and simplifying administrative burdens in environmental regulations. As its first step, it gathered comments in a recent stakeholder consultation.
The associated Call for Evidence states that ‘the Commission is currently screening environmental laws to identify legislative acts with significant potential for simplifying administrative tasks. The aim is to reduce the administrative burden without affecting the environmental objectives agreed under the existing legislation’.
Everyone in the electronics industry can agree—I hope—that the Europeans have a leadership position in regulating the environmental performance of products as well as in the overall and aggregated complexity of these regulations. This complexity has resulted in some extraordinary inefficiencies that manufacturers and their supply chains have had to deal with.
Stated examples of measures that the EC may take include: discontinuation of the SCIP database; harmonization of the provisions for authorized representatives for EPR in each member state; and streamlining reporting obligations.
While fixing a lot of the problems with EPR (ie WEEE) throughout the EU should be high on everyone’s list, most interesting is the potential for elimination of the SCIP database. I’ve never believed this database has much merit to begin with. What little it might have is certainly not commensurate with the extraordinary efforts and expenses that manufacturers and their supply chains have had to expend to produce data that, if not necessarily accurate, is acceptable to the extraordinarily rigid structural and data-intensive system.
The sad thing is that the defined purpose of the SCIP database—to enable recyclers to identify parts and materials that would need to be removed from products they receive in order to be separately treated—is a mere pipe dream. No recycler is going to spend time researching each item received in the SCIP database then disassembling it down to the specific bits and pieces that may contain SVHCs. They have neither the time nor resources to do that, but they do have a giant shredder that everything gets tossed into. I thought that a less unlikely purpose of the data may be to help the EC understand where certain SVHCs are used, but not only is the user interface too clumsy for that; they already have resources in the JRC or elsewhere, plus the ability to require information to be provided from industry to answer those questions.
So, work with peers, suppliers and industry associations to develop metrics about how much time, money and human resources obtaining the data then generating and submitting the i6z files to the SCIP database has taken for your company: if it can even be quantified. Make sure the EC gets the message about the lopsided cost to manufacturers of providing the information into the SCIP database with insufficient evidence that the data is useful or usable by anyone for any particular environmental reason.
Switching subjects, the Stockholm Convention has been working on whether to list medium-chain chlorinated paraffins (MCCPs) as a persistent organic pollutant (POP). Recall that MCCPs were being considered for addition to EU RoHS as another restricted substance but that was formally abandoned last December.
At its most recent meeting, the Conference of the Parties to the Stockholm Convention on Persistent Organic Pollutants decided to amend Part I of Annex A (Elimination) to include MCCPs with specific exemptions, as documented in Decision SC-12/10, the Stockholm Convention. Note that these exemptions include wires and cables in the construction sector and medical device/in-vitro diagnostic devices as well as some other purposes until 2036.
The next step is for all the Parties to the Stockholm Convention to transpose this decision into their local regulatory structure. So, expect to see every market, except the US (which never ratified the Convention) and Israel (which may now be moving toward ratifying the Convention) implement this ban over the next few years.
Now a selection of quick takes.
Australia: Decabromodiphenyl ethane (DBDPE), the common drop-in replacement for decabromodiphenyl ether (DecaBDE), has now been banned per Compilation No 4 of the Industrial Chemicals Environmental Management (Register) Instrument 2022. Schedule 6 indicates it comes into effect on 1 January 2027. There are some exemptions, including for electrical and electronic equipment until 1 July 2037, as it is (curiously) viewed as an ‘essential use’. DecaBDE is also restricted in this same section to 1000ppm in some applications but allowed at levels up to 10 per cent by weight until 1 January 2027.
Minnesota: The PFAS reporting due date has been extended from 1 January 2026 to 1 July 2026. Don’t forget to budget for submission of your initial report.
US: EPA has again delayed the one-time TSCA Section 8(a)(7) PFAS reporting period to begin on 13 April 2026 and continue for six months to 13 October 2026 (small manufacturers only reporting as PFAS article importers have until 13 April 2027).
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Michael Kirschner is a regular contributor to TTI Inc.’s MarketEYE. Read more from Michael and other experts at tti.com/MarketEYE.
