SCIP And PCN Databases
In 2021, new reporting obligations of suppliers of some selected products as well as chemical substances were put in place in the Slovak Republic. In view of the recently introduced fines, companies particularly in the automotive, electronics and manufacturing sectors, are recommended to increase their vigilance, as failure to comply with the notification requirements can result in fines of up to EUR 80,000.
- Information for CFO
- Information for Persons Responsible for Reporting
- Information for Persons from Sales Departments
Information for CFO
- The newly implemented reporting obligations apply to products containing hazardous chemicals (SCIP database), as well as chemicals as such (PCN database).
- Manufacturers and importers of products in particular are obliged to submit specified information to the SCIP database, but simplified reporting obligations also apply to other entities in the distribution chain besides retailers and sellers to final consumers.
- Compliance with these obligations is in line with ESG policies and a positive environmental image of society.
- In case of non-compliance with the reporting obligations, fines of up to EUR 80,000 are imposed by the Slovak Trade Inspection.
How can PwC help you?
- We will go through your complete product portfolio to make an analysis of your reporting obligation.
Information for Persons Responsible for Reporting
- The new reporting obligation in the SCIP database applies to products containing hazardous chemicals and/or substances of very high concern higher than 0.1 % by weight.
- It is required to collect information on the chemical composition of the products your company uses in its business operation, and to compare this information with the Candidate List of Substances to identify products containing hazardous substances above 0.1 % by weight. Information about such products must be submitted to the SCIP database. In the case of component products, the composition of individual components should also be considered.
- The list of mandatory reporting substances is continuously expanded; therefore, the check shall be performed regularly.
How can PwC help you?
- We will compare chemical composition of your products with the Candidate List of Substances to identify which products are subject to the reporting obligation.
- We will help you register your company with ECHA and will assist you with the reporting itself.
- We will ensure that your product portfolio is regularly checked for updated lists of hazardous substances.
- Companies often face problems when a supplier is reluctant to provide information on the composition of a given product. We will help you avoid these situations and/or effectively address them.
Information for Persons from Sales Departments
- The EU REACH Regulation requires suppliers of products containing hazardous substances to provide information to customers to enable a safe use of these products.
- Companies are required to communicate information on hazardous substances in their products to customers in an appropriate manner.
How can PwC help you?
- We will check whether this obligation applies to you and whether the way of reporting information on hazardous substances in your products is appropriate.
- We will help you set up provision of information on hazardous substances either directly on the product or in the package leaflet, or we will help you implement other appropriate methods of providing information.
From the beginning of 2021, it is required to submit information on chemicals hazardous to human health or the environment to the PCN database (Poison Centres Notifications). At the end of 2021, additional obligations were added in the Waste Act, which are related to the reporting of products to the SCIP database (Substances of Concern in Articles). Both databases are managed by the European Chemicals Agency (ECHA).
Products containing hazardous substances above 0.1 % by weight shall be reported in the SCIP database. This results in an obligation for companies to collect information on the chemical composition of the products they manufacture or sell. This composition shall be compared with the list of hazardous substances, the so-called Candidate List of Substances, maintained by ECHA. If the content of these substances in the products exceeds 0.1 % by weight, the products must be reported in the SCIP database. In the case of component products, the components themselves also need to be known and communicated. The list of hazardous substances is continuously expanded; therefore, the chemical composition of products shall be checked against the ECHA list on a regular basis.
This reporting obligation mainly concerns manufactures and importers of products. However, simplified reporting obligations also apply to all subsequent stages of distribution chain with the exception of sellers to final consumers and retailers. The reporting obligations do not depend on the size of the company, and cannot be waived even if the product has already be reported by another entity in the distribution chain.
