Companies have already been able to familiarise themselves with the SCIP database on the basis of a prototype, including the possibility to enter “test notifications”. However, these “test notifications” will be deleted again on 05.01.2021 and thus do not lead to the fulfilment of the reporting obligation. With the release of the SCIP database in the last week of October, companies subject to reporting obligations now have about two months to submit the necessary reports until 05.01.2021.
In the context of the announcement of the launch of the SCIP database, ECHA again emphasizes that it cannot be assumed at present that the reporting deadline will be postponed.
Even if the details of the implementation of the notification obligation in Germany cannot be foreseen at present (see already: Reporting obligation for SVHCs implemented in German law), radical deviations from the ECHA requirements are not to be expected. Even though the legal ordinance according to Sec. 16f para. 2 ChemG is still pending, the preparation of the SCIP notifications can and should be started as soon as possible or continued continuously in order to ensure timely reporting.
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