Dr Dipl.Chem. Beate Kummer provides Auto Recycling World with her expertise on substances of concern in products (SCIP) and what this means for the auto recycler.
SCIP stands for “substances of concern in products” and is a new database set up by the European Chemicals Agency (ECHA). It contains information on “substances of concern” in products. This information will be made available to waste recyclers from September 2021. The main target of the database is to finally remove such hazardous substances from the economic cycle and thus come a step closer to the EU Commission’s goal of a “Tox-Free Environment”. It has been online since January 2021.
SCIP aims to collect information on substances of high concern in articles or complex products (such as lead stabilisers or plasticisers in plastic components, brominated flame retardants in electronic equipment, polyaromatic hydrocarbons in tyre granules, etc.). The database has its EU legal basis in the Waste Framework Directive (WFD).
For suppliers of an article containing substances on the Candidate List, Article 9 (1) (i) of the WFD, subsequently provides for corresponding notification obligations to ECHA. The so-called Candidate List (Annex XIV of the REACh Regulation) currently contains about 200 substances that must comply with the criteria of Article 57 of the REACh Regulation. An “article” is an object that contains a specific shape, surface or design during production (e.g. cable or screw on a printed circuit board). This definition can be found in Art. 3 of the REACh Regulation, and “complex objects” will soon also be affected by the reporting obligation. These, in turn, are products consisting of more than one product (e.g. printed circuit board).
The request of the EU Commission to provide recycling and waste management companies with more information on substances of concern is correct. In most cases, disposal companies today do not know which substances of concern are contained in the waste to be disposed of (e.g. electronic scrap, batteries or packaging) when it arrives at the recycling plant. The EU Commission now wants to counter this with SCIP. The aim is to create more transparency regarding the composition or presence of hazardous substances in complex products, and this is fed by the manufacturers who can still use hazardous substances today – in some cases with legally regulated exceptions (e.g. lead in various compounds).
Example data supplier automotive industry: Since the first regulations on end-of-life vehicle recycling came into force, the automotive industry has relied on IMDS – International Material Data System as a database for materials and components. According to its own information (T.Unger, 2020), it has cost the European industry around 10 billion euros to establish the database. Anyone who asks the operator can get access.
In the IMDS material data, the material and chemical compositions of components, semi-finished products and materials are declared. The main use of the IMDS material data is to secure and prove legal substance regulations for complete vehicles and their spare parts.
Furthermore, IMDS material data are used as a data source for the calculation of the recycling rate according to ISO 22628 in the system approval of the EU type approval. Currently, IMDS is accessed by about 130,000 active users, and about 14,000 substances are reported. Besides aircraft, passenger cars are certainly the most complex products affected by SCIP. The establishment of SCIP now means that all necessary information on svhc has to be obtained from suppliers in the EU and outside the EU for thousands of individual affected items per vehicle. In the figure below, an electronic component from a vehicle is used to illustrate (see Fig.1) that even the designation of an “article” or product is not easy because there are often no generally valid proper names. The European automotive industry expects several billion Euros for this complex data collection for substances of very high concern because the current IMDS structure is not usable
Example data users in the recycling industry: The nature of today’s recycling technologies (e.g. dismantling facilities for end-of-life vehicles and shredder plants) will hardly allow for the determination of individual material information for each component of a vehicle regarding questionable materials in day-to-day business. Hundreds of different vehicle models of the most varied composition are usually disposed of in one plant. What counts here is essentially a high throughput in tonnage to ensure economic recovery in view of the raw material price situation.
If questionable substances have to be removed from individual “mining products” (such as screws, solder contacts) in the future, economic recovery is practically impossible because simply checking for the presence of questionable substances will take far too long. This applies not only to vehicles but also to many other complex products.
Furthermore, the question must be answered, is this even necessary to achieve the EU’s “Tox-Free-Environment” goal? For example, the svhc material lead as an additive in steel alloys changes into the gaseous aggregate state during the recycling process and does not remain in the melt. The separation of individual alloying elements is thus carried out automatically.
Electronic scrap is treated separately by specialised recyclers in accordance with the
WEEE Directive, and manufacturers already provide the information required by Article 15 of the WEEE Directive (e.g. via the I4R platform). In the recycling process, only very specific components (such as batteries) are removed manually before the remaining parts go through the sorting and treatment processes. In complex electronic devices, the substance of very high concern is usually present in very small quantities in small sub-particles of the product.
Detailed information about these tiny sub-particles (product category, material category) is not helpful for recyclers because knowing the presence of svhc substances would usually not change the final, often metallurgical treatment process. Some svhc materials (e.g. organic hydrocarbon compounds) do not survive the recycling process at all; the high process temperatures destroy them.
Is there an alternative to SCIP?
To meet the goals of the EU Commission in the area of climate protection and resource conservation, there is no alternative to more recycling and higher use of recycled raw materials. To solve the “pollution problem” in waste, more trust in the economy is necessary. Today, there are many restrictions on pollutants, which are already regulated in chemicals, substances and waste legislation. Here are just a few examples, all of which must be applied when placing new products on the market: Toys Directive, End-of-Life Vehicles Directive, Electronic Scrap Directive and ROHS (EU Directive 2011/65/EU serves to restrict the use of certain hazardous substances in electrical and electronic equipment), Packaging Directive, substance restrictions in Annex XVII of the REACh Regulation, POP Regulation.
The application of all of the regulations mentioned above already existing today will gradually – in connection with REACh – lead to the fact that substances of less and less concern will also arrive in waste management. Even today, there are hardly any cases in which recycled waste has led to a pollution problem in production. Today, the much greater challenge is to bring more waste into high-quality recycling to save more, especially non-renewable resources. In the worst case, SCIP will lead to even more pollutant removal in recycling, when it will then lead to even more disposal of waste streams. As a result, large amounts of valuable resources will be lost, which are also necessary for successful climate protection.
The chances of changing the SCIP database can currently be classified as extremely low, so manufacturing companies are well-advised to look into the matter (https://echa.europa.eu/de/scip-database) and, if necessary, to consult external scientific advice.