In May 2020, EDA launched a new study on the impact of (other than REACH and CLP) EU Chemicals and Waste Regulations on defence.
Article 9(1)(i) of the revised Waste Framework Directive (WFD) established a new requirement to ensure that the information on articles containing SVHCs is available throughout the whole lifecycle of products and materials, including at the waste stage. Considering the high complexity of defence systems and their corresponding supply chains, potential impacts for defence stakeholders can already be foreseen in some scenarios involving components provided by higher-tier suppliers, cross-border supplies and dual use products. Moreover, there is the potential security risk that military classified information - e.g. on detailed product composition - is provided to the SCIP (Substances of Concern In Products) database and published by ECHA.
Since the implementation of SCIP database is just starting, it is still very unclear how the system will finally work. The dedicated SCIP activity at the EDA level further builds a common understanding of WFD/SCIP requirements, exchange best practices in the regulation implementation, and elaborate solutions to implement the SCIP requirements.
Key activities foreseen
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- Complete the mapping of the transposition of Article 9(1)(i) WFD on SCIP notification in all of EDA participating Member States;
- Discuss possibilities to harmonise the application of national provisions governing SCIP implementation in the area of defence, where the Member States’ provisions are similar;
- Where needed, collaborate on appropriate solutions for defence products and components (e.g. work on a defence-sector recommendations to address WFD Article 9/SCIP database and a new EDA Code of Conduct).
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