Value chain impacts of EU waste framework directive 2018/851 as a result of reporting substances of very high concern from 2021

Abstract

The EU Waste Framework Directive 2018/851 sets out requirements for producers and importers of products within the EEA, to report data on Substances of Very High Concern (SVHC) content within products into a new central European database to from 5th January 2021. The reporting requirements: (1) support chemical regulations that impose the need on industry to record the use of hazardous chemicals; (2) identification of products entering waste streams containing hazardous chemicals; (3) support circular economy initiatives within the EU. To meet these new reporting requirements industry will need to collect additional information from all supply chain actors, who as duty holders will also be required to report into the new EU SVHC database system. Failure to provide the required information may result in enforcement actions from the authorities, which could see products being restricted from the EEA. The new EU database system will be accessible to industry, regulators, NGOs and the general public. This paper explores the new requirements, together with feedback received from various stakeholders for collection of data and reporting into the new EU database system from 2021.