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.
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.
