Echa's plans for a database on candidate list substances in articles would place "unnecessary burdens" on industry and add "little benefit" to waste operators, according to automotive, aerospace and recycling sector groups.
The proposal to develop the database came out of the revised waste framework Directive that entered into force in July. A consultation on the database closed on 9 October.
The proposed database would contain information submitted by companies producing, importing or supplying articles that contain candidate list substances. They will need to submit this information for articles placed on the market from 5 January 2021.
The aim of the database is to strengthen supply chain communication as foreseen under REACH and contribute to the EU's circular economy package. Primary users of the database would be waste treatment operators and consumers.
The database, as set out in the revision of the Directive, requires a company, at a minimum, to declare the presence and name of any SVHCs in an article. However, Echa has published a 'draft scenario' which includes proposals for the database, including unique identifiers for each article and more detailed information such as the concentration limits of SVHCs in the articles.
Steve George, chair of the REACH and chemicals management working group of the European aerospace and defence industries association (ASD), told Chemical Watch that the implications of this "article-centric approach" has very wide consequences that will result in "widespread non-compliance across all industry".
Mr George said this is due to the "implicit requirement to redesign long-established design and production working practices, together with changes to associated company IT infrastructure."
And Timo Unger, environmental manager at Hyundai, told Chemical Watch the database will require all of industry to change their "parts development, purchasing and quality systems to name just a few". A car, he says, consists of hundreds of thousands of articles and to obtain unique identifiers for each article and then input information about those that contain SVHCs is not possible.
A car manufacturer could potentially have millions of articles in its product portfolio, he says. "No industry system can manage this level of information and so systems would need to be redesigned."
"This is likely to cost billions of euros," he said.
Mr Unger agreed that the database requirements present risks of non-compliance because this additional data is "very difficult to collect, especially from non-EU suppliers and in particular for small and medium sized enterprises (SMEs)".
He added that the database pushes the idea of a 'one-size-fits-all' solution. "You cannot compare a milk bottle with a car. The same information requirements for complex products cannot be the same as those for simple products, it just doesn’t make sense," said Mr Unger.
The European recycling industry association (EuRIC) has also raised concerns. In a position paper it says the amount of information needed to be made available by such a database is "likely to be overwhelmingly high".
"The level of detail needed by recyclers depends very much on the type of articles at stake and the treatment process for this article," the paper adds.
It explains that waste treatment officers will only benefit if the data can easily be accessed by product and sub-product categories. This will allow managers at waste treatment facilities to "easily access the necessary information and adapt the treatment processes, if necessary".
In addition, the database will not solve the issue of legacy substances in articles, says EuRIC. "Manufacturers will only declare the SVHC content of articles put on the market when the substance in question is formally identified as an SVHC."
This means, it adds, if a substance is identified as an SVHC, and is present in an article already placed on the market, recyclers will not get any information on the substance.
However, EuRIC supports the principle behind the database and welcomes the idea that it will "centralise information", "improve the traceability of substances in waste streams" and its potential to improve the safety of workers in recycling facilities.
The sector groups, along with other stakeholders, all participated in the consultation on the database. Echa is inviting member state representatives and other stakeholders to its workshop in Helsinki on 22-23 October. Here participants will discuss the agency's scenario document and next steps.