The Circular Economy Is Looping Around for all EU Manufacturing and Importers In 2021

Preparations for the EU Waste Framework Directive (WFD) database are gathering steam, especially with the European Chemicals Agency’s (ECHA’s) recently published “Detailed information requirements for the SCIP database.”

Under Article 9 of the WFD, ECHA is required to have the SCIP database in place by 5 January 2020 and ready for data submission beginning 5 January 2021. This will be a major undertaking for many industries but it will in theory be beneficial to the EU economy overall.

Read on to learn what role maintaining a database of the substances of concern in articles or in complex objects (products) (SCIP) will play in supporting a circular economy the EU is working toward.

 The Problem of Hazardous Materials in the Circular Economy

As the global population continues to rise, our traditional linear model of consumption (take-make-use-dispose) is increasingly seen as unsustainable. Our world’s growing middle class paired with the corresponding growth of consumption is placing expanding pressure on the world’s finite resources.

The circular economy seeks to meet this problem with a more sustainable model of consumption. Using a model of manufacture-consume-recycle-reuse, previously-used resources would be continually cycled back into the manufacturing process rather than falling to waste.

But hazardous substances in secondary materials are a key barrier to realising a circular economy. How do recyclers know the hazardous substances of a product being recycled in order to handle and reprocess the product safely? How do recyclers avoid incorporating hazardous substances into recycled secondary materials?

The Importance of Transparency Regarding Hazardous Materials

To increase our ability to create a sustainable circular economy, we must take a multi-pronged approach in dealing with hazardous materials that can pose a threat to the reuse of recyclable materials. In order to safely deal with hazardous materials, recyclers should be provided with greater transparency about which materials contain hazardous substances. This will allow them to protect the safety of their workers and prevent contaminating recyclable materials with hazardous substances. This is where the importance of accuracy and transparency of inputting substance information into the WFD database is evidenced.

Another part of the solution is to encourage manufacturers to stop using hazardous substances in their products in the first place. This can be achieved by legal measures –  e.g., the End of Life Vehicles (ELV) heavy metals restrictions on lead, mercury, cadmium and hexavalent chromium in vehicles), but it can also be encouraged through consumer pressure. By giving consumers information on the hazardous substance content of products, they can make informed decisions and stimulate the market to provide products with lower hazardous substance content. This, in turn, would reduce the hazardous substance content of products when these products eventually become waste.

Where the WFD Database Fits Into This

Under Registration, Evaluation and Authorization of Chemicals (REACH), there are already requirements for producers and importers of articles to inform ECHA about a Substance of Very High Concern (SVHC). But the WFD database will theoretically help address the current lack of transparency regarding hazardous substances for both ECHA and the general EU population.

For instance, under REACH’s Article 7(2) Notification, producers or importers of articles are required to notify ECHA when the articles they are placing on the market contain more than 0.1% SVHC and the tonnage being placed on the market exceeds more than one tonne per annum. But this does not apply if the substance is already registered for the same use it is being put on the market for; nor if exposure can be excluded.  As a result, ECHA has received very few notifications and their information about where SVHCs are being used in products is limited.

Under Article 33(1) of REACH, any SVHC content in an article above 0.1% must be communicated to the next recipient in the supply chain in order to handle it safely. Additionally, Article 33(2) provides consumers with the right to request information on the SVHC of a product, together with safe use information.

But this places the onus on the consumer to make the request, which will more often than not act as a barrier for the consumer to obtain the SVHC content information.

But while Article 7(2) and Article 33 require information about hazardous material content to be provided to ECHA and consumers, it does not require the same information to be given to waste operators. This becomes a problem when a product with hazardous materials reaches the end of its life cycle.

To address this problem, ECHA anticipates using the WFD database to create an article-centric approach that can be accessed by consumers at the purchasing stage and accessed by waste operators after. All articles that are within the scope of Article 33 (those that contain SVHCs above 0.1%) would be reported into the system at the lowest tiers of the supply chain by EU manufacturers or importers. As those articles are assembled into more complex configurations and ultimately products, the database would be updated accordingly by the obligated party.

The figure below from the Workshop on Waste Framework Directive database-Proceedings illustrates how ECHA envisions the database being used.

Ultimately, this would allow waste operators access to the database and provide them with the ability to identify articles containing hazardous materials. As a result, they will better be able to protect their workers’ health and avoid contaminating recyclable materials with hazardous substances.

Consumers would also have access to the database, allowing them automatic access to information regarding hazardous substances instead of having to specially request it. This will allow them to make informed purchasing decisions, which will, in turn, encourage manufacturers and their suppliers to veer away from using hazardous substances in their products. ECHA will also be able to use the collated data to inform future decisions on regulating substances. So, what’s in store for your manufacturing operation?

Required WFD Database Inputs

EU manufacturers and importers will be required to report articles as such (e.g. an O Ring) or as part of complex objects (e.g. a car engine) that contain REACH SVHCs. The recently published detailed information requirements for the SCIP outlines both the mandatory and optional data that is to be input for articles and complex articles.

See the chart below for the mandatory fields of the SCIP.

Article name Main name assigned to the article as such or the complex object; free text
Primary Article Identifier Numerical or alphanumerical identifier assigned to the article as such or the complex object and identification of its type. The primary Article Identifier will be used to support the preparation of a notification.

Type options: e.g. European Article Number (EAN); Global Trade Item Number (GTIN); Universal Product Code (GPC); Catalogue number; ECHA Article ID, part number.

Article category* Identification of the article as such or the complex object from a harmonised list (with codes and description) which cannot be achieved by the article name(s) assigned, until a certain level of granularity, based on function/use. It is important to identify certain relevant waste streams.

Allowed values: The integrated Tariff of the European Union – TARIC – list, based on the Combined Nomenclature (CN) description and code [Annex I to Council Regulation (EEC) No 2658/87] (the relevant descriptions and codes must be selected).

Production in European Union In this field, the duty holder answers to the question: is the article produced or assembled in the EU?

Allowed values: yes; no; unwilling to disclose

Safe use instruction(s)* Safe use information. It includes the possibility to state that there is “No need to provide safe use information beyond the identification of the Candidate List substance”.
Linked article Add a link to an existing article or create a new article or a complex object to link with this complex object.
Number of units Number of occurrences of the linked article in the complex object
Candidate List version Identification of the Candidate List substance version based on which the information on the article as such or complex object has been assessed against before being submitted to ECHA
Concentration range Possible concentration ranges of the substance in the article:

 > 0.1% w/w and < 0.3% w/w;

 ≥ 0.3% w/w and < 1.0% w/w;

 ≥ 1.0% w/w and < 10.0% w/w;

 ≥ 10.0% w/w and < 20.0% w/w;

 ≥ 20.0% w/w and < 100% w/w;

 > 0.1% w/w and ≤ 100% w/w.

Material category Identification of the material the article (containing the Candidate List substance) is made of from a list to be provided by ECHA.

[It is important to identify certain relevant material-based waste streams. It also allows the identification of the article based on the material it is made of.]

Mixture category Identification of the mixture category from the European product categorisation system (EuPCS) containing the Candidate List substance(s) incorporated in the further processing step (e.g. coating) of an article or incorporated when joining or assembling two or more articles in a complex object (e.g. adhesive, solder).

[It allows to identify where in the article the Candidate List substance is present.]


For help preparing to input data for the Waste Framework Directive database, contact our REACH experts.


Start Preparing Your Materials Data Now


Is the UK crashing out of the EU on 31st October?

Three years have passed since UK voted to leave the EU on 23 June 2016 by a majority of 51.9% to 48.1%. Despite the UK triggering Article 50 to initiate the formal exit process with a leave date set for the 29 March 2019, the UK remains within the EU until at least the extended Article 50 deadline of the 31 October 2019.

 In this update following his recent two-part series, Will Martin, a Tetra Tech partner with expertise in product compliance requirements particularly in the UK, provides an update on the past turbulent weeks for UK politics and assesses the likelihood of No-deal Brexit.

 Prime Minister Boris Johnson’s Turbulent First 3 Months

Following his election by the Conservative party as leader, Boris Johnson took office as Prime Minister on 24 July. Continuing his bullish stance to leave the EU on the 31 October “come what may”, a turbulent three months have passed as the deadline loomed.

In Johnson’s first act, he dismissed 11 senior ministers and accepted the resignations of six others from Theresa May’s cabinet, installing ministers who are predominantly leavers and committed to his stance of leaving the EU on the 31st deadline with or without a deal[1]. Johnson also installed Dominic Cummings, mastermind of the winning 2016 leave campaign, as chief advisor. The government then set about raising the profile of no-deal Brexit preparations to increase pressure on the EU to revisit the controversial Irish backstop arrangements which proved to be the major stumbling block of Theresa May’s deal.

Johnson’s most controversial move was on the 28 August announcing he had asked the Queen to prorogue Parliament from 10 September to 14 October (24 sitting days) —the reason stated as to allow the new government time to plan the next session of Parliament. An angry backlash followed from politicians and the “remain” general public as this was viewed as a cynical ploy to prevent Parliament from holding the government accountable leading up to the 31 October deadline. Proroguing normally shuts down Parliament for a much shorter period and certainly never in times of political crisis (e.g., 4 days in 2016, 13 days in 2014[2]).

In response to the impending shutdown of Parliament, the Benn Act was passed by opposition members within Parliament that legally requires the government to request a three-month extension to the 31 October deadline from the EU should no deal be agreed by the 19 October. Included in those opposition members of Parliament were 21 conservative party members who were duly sacked by Johnson for not toeing the party line. This prompted one of Johnson’s cabinet, Amber Rudd, to tender her resignation on the 7 September in protest against the sackings while also citing concerns that the government was putting only limited effort into securing a new deal with the EU, instead focusing on no-deal preparations[3].

Legal challenges to the prorogation were brought, culminating with a Supreme Court ruling on the 24 September where it was unanimously found that Johnson’s advice to prorogue Parliament was unlawful. The Court’s president, Lady Hale, said the suspension “had the effect of frustrating or preventing the ability of Parliament to carry out its constitutional functions without reasonable justification”[4]. The prorogation was rendered null and of no effect, and Parliament duly returned on the 25 September.

The upshot of this aggressive approach is that the government currently does not have a working majority in Parliament. Due to the sackings and defections of Conservatives to other parties, the government has a majority of minus 23, making it difficult to pass legislation. Johnson lost all seven of his first votes as Prime Minister demonstrating the current weakness of his position.

The Boris Johnson Deal

Despite the rhetoric and public statements about preparing for no-deal and leaving on the 31 October come what may, Johnson’s government presented new proposals to the EU on alternative arrangements to the Irish backstop and a new political declaration on the future trading relationship between the UK and EU.

A revised Brexit deal was duly agreed at the European council summit in Brussels on the 17th October.

The key differences between Boris Johnson’s deal and Theresa Mays deal relate to the Northern Ireland backstop arrangement, and the political declaration on the future trading relationship between the UK and the EU.

Northern Ireland Backstop Change

Should no deal be reached on the future trading relationship by the end of 2020 the whole of the UK will leave the EU customs union which would allow the UK to be able to strike trade deals with other countries.  There would be a legal customs border between Northern Ireland and the Republic of Ireland, but in practice the customs border will be between Great Britain and the island of Ireland.  Goods deemed at risk of being destined for the EU will have any duty applicable collected at that border.  For goods, N. Ireland would keep to the rules of the EU single market, rather than UK rules.  That would remove the need for physical product standard and safety checks on goods at the border between Ireland and Northern Ireland as both countries will be in the same regulatory zone.  EU value added tax (VAT) will apply in N. Ireland for goods, meaning that VAT rates in Northern Ireland and the rest of the UK could diverge in the future[5].

These arrangements are highly controversial as it treats N. Ireland differently from the rest of the UK.  Boris Johnson himself stated in November 2018 at the Democratic Unionist Party (DUP) conference:

“We would be damaging the fabric of the Union with regulatory checks and even customs controls between Great Britain and Northern Ireland, on top of those extra regulatory checks down the Irish Sea that are already envisaged in the withdrawal agreement,” he told the DUP party conference in November 2018.

“Now I have to tell you, no British Conservative government could or should sign up to any such arrangement.”[6]

Johnson has then gone back on his word but the deal does give the N. Ireland Assembly a say in whether or not this arrangement continues, assuming no agreement on the future relationship between the EU and UK is reached that would replace the arrangement.  Four years after the end of the transition period, January 2025, the N. Ireland Assembly would have a vote on whether to continue with the provisions.  The DUP has voiced concerns that N. Ireland risks being locked into the arrangement indefinitely as they would have no guarantee of reaching a majority in the Assembly to discontinue the arrangement.  Nationalist would likely want to continue to be more closely aligned with the Republic of Ireland, and N. Ireland as a whole voted predominantly to remain in the EU in the 2016 election.  That could ultimately steer N. Ireland towards unification with the Republic of Ireland. The ‘special treatment’ of N. Ireland remaining closer to the EU than the rest of the UK has also given weight to Scotland’s growing calls for a second referendum on leaving the UK.  Scotland also voted predominantly to remain in the EU in the 2016 referendum and are not in favour of the hard Brexit being proposed by Boris Johnson’s deal.

Political Declaration Change

Whilst much of the text of the political declaration remains unchanged from Theresa Mays deal there are crucial differences.  Mays deal committed to close regulatory alignment to lead to minimal disruption to trade between the UK and EU.  Having similar regulation in the UK and EU would allow ongoing industrial regulatory co-operation and prevent many types of checks on trade.  Under Johnson’s deal references to a “level playing field” have been removed, instead saying that the UK and the EU should “uphold the common high standards […] in the areas of state aid, competition, social and employment standards, environment, climate change, and relevant tax matters”[7].  Johnson’s deal is a hard Brexit with the UK leaving the EU’s common market and customs union to replace it with a Canada style free trade agreement.  That gives more flexibility for the UK to strike deals with other countries such as the US, but the trade-off is more customs checks and bureaucracy resulting in the loss frictionless trade with the UKs largest market, the EU.  Checks on goods at borders between the UK and EU will be inevitable under such an arrangement which backs up the DUPs concerns that customs border down the Irish sea would become a permanent fixture under Johnson’s deal.

Industry Feedback on the Johnson Deal

The aerospace, automotive, chemicals, food and drink and pharmaceutical sectors sent a letter to the government highlighting their concerns about the impact that Johnson’s deal would have on their operations.  In particular, weakened commitments to maintain regulatory alignment, and that the UK may no longer participate in specific EU regulatory institutions after any Brexit deal[8].

As described previously in this series, manufacturing operations in the UK have supply chains that are tightly coupled to continental Europe and rely heavily on the free and frictionless trade the UKs membership of the EU currently offers.  It was indeed the UKs membership of the EU that attracted the likes of Honda, Nissan, Toyota and other non-EU global manufacturers to invest in the UK in the first place.  The shift towards regulatory divergence and consequent steps away from frictionless trade make the UK less attractive in the long-term.  Manufactures also make the point they will still need to comply with EU regulation and standards as the EU will still be a significant market for them, but will also need to comply with diverged UK regulation adding complexity and cost to their operations.

Whilst references to European Medicines Agency (EMA), the European Chemicals Agency (ECHA), and the European Aviation Safety Agency (EASA) remain in the revised political declaration, commitment to participate in these institutions is watered down with a clause being removed that the UK will consider aligning with those agencies’[9][10].  Theresa May confirmed to parliament that she would seek UK membership of these agencies whereas the Johnson government has not offered similar assurances, only that ‘the government is seeking a “best in class” free trade agreement, where the UK would set its own regulatory standards’[11].  The aerospace industry body ASD has stated “regulatory divergence would pose a serious risk to our sectors” will result in “huge new costs and disruptions to many of our member companies”, and an “inability to shape safety rule making” which “will make it much more difficult to bring UK technology to market”[12].

The government’s own economic impact assessment of a Canada style trade deal published to coincide with Teresa Mays deal, estimated the UK would lose 6.7% GDP growth between now and 2034 compared to remaining within the EU[13].

It is notable that whilst industry has been highly vocal on the impacts of no-deal Brexit, most recently with Nissan warning no-deal Brexit could make their European business model unsustainable[14], this is the first time industry has expressed concerns about the envisaged future trading relationship.  A recent survey conducted by the SMMT found that Brexit is already impacting automotive with 11.8% of firms saying they had already divested from their UK-based operations, and 13.4% relocating operations overseas.  Furthermore, they found three quarters (77.2%) of firms stated there has already been a negative impact on business even before the UK has left the EU[15].

Likelihood of No-Deal

In the latest twist to the convoluted Brexit tale, Johnson putting his new deal to a vote to ratify his new deal in Parliament on Saturday 19th October, an amendment to delay the vote until its implementing legislation had passed through the Parliamentary process.  That ensured that the Benn Act 19th deadline passed, requiring Boris Johnson to send a letter to the EU to request an extension to the 31st October deadline in order to avoid a no deal Brexit.  This he duly did, albeit without signing the letter, and sending with it a second letter arguing that the EU should not grant an extension.

The government is still intending to press on passing the legislation through the House of Commons and House of Lords in time to leave by the 31st October (assuming that Parliament approves the deal at the end of that process).  To that end the government is tabling a bill to parliament to pass the 110 page European Union (Withdrawal Agreement) Bill in just three days, a process which would normally take several weeks.

If the government is unsuccessful in their bill to approve the WAB timetable, it seems highly likely the 31st October deadline would not be possible, and the EU would need to grant an extension.  The EU has already intimated this would be possible, with president of the European council Donald Tusk stating to the European parliament that ‘a no-deal Brexit will never be our decision’.

A no-deal exit from the EU then seems unlikely, at least at the end of October.  The government may be forced to request an extension beyond the 31st October, to finalise the WAB, then have a vote on the Johnson deal, which will then also need to be approved by the European Parliament paving the way for the UK to leave the EU and enter the transition period.

Whilst the government is still in a minority, opposition MPs have the potential to disrupt the government’s plans.  This could comprise adding amendments to the withdrawal bill such as requiring the UK to remain in a customs union with the EU, attaching a confirmatory vote to the Johnson deal, or requesting an extension to the transition period for one to two years to ensure sufficient negotiating time for the trading arrangement between the UK and EU.

Should any of these amendments pass that require Johnson’s deal to be re-negotiated, it is highly likely that rather than go back to the EU, the government will seek a general election.  They can then campaign on the promise of exiting the EU with his deal or without a deal, hoping to secure leave voters with the remain voters being split across Labour, Liberal Democrats, Green and SNP parties.  With a majority in parliament reinstated, Johnson could then deliver his deal through Parliament with a majority in place to smooth its progress.  That would be highly preferable over a second referendum as the Conservative government would only need to secure around 33% of the vote as opposed to over 50%.

The run up to the end of October will be a crunch point for Brexit.  In the coming days and weeks, we should finally have clarity on whether or not the UK will leave the EU, and under what terms, for better or for worse.  It should be stressed though that far from Johnson’s slogan of ‘getting Brexit done’, if his deal is passed it will be just the start of EU negotiations on the future relationship, something which will continue for many years to come.  Hopefully though some lessons will be learnt as to the efficacy of attempting to address highly complex, interconnected issues around sovereignty, immigration, trade, and regulation with a simple yes or no question.

To strengthen your product compliance strategy that can stand up to any upcoming Brexit situation, schedule a UK training on IMDS and/or REACH requirements. Details of upcoming IMDS and REACH training courses in the UK can be found here.




















Stifle Commercial Kitchen Fires with Compliance

Fires are ravaging commercial kitchens across the service industry, burning through safety, productivity and profits.

In fact, in the UK during 2017/2018, there were 1,638 reported commercial fires within food and drink premises which were believed to have originated from kitchens (

Statistics Restaurant Owners Should Know

During 2006-2010, an estimated average of 7,640 structure fires in eating and drinking establishments were reported to U.S. fire departments per year, with associated annual losses of:

  • 2 deaths
  • 115 injuries
  • $246 million in property damage

Structure Fires in Eating and Drinking Establishments by Major Cause, 2006-2010 also shows us commercial kitchens’ greatest risks:

  • Cooking equipment 57%
  • Heating equipment 10%
  • Electrical/Lighting equipment 7%
  • Smoking material 7%
  • Intentional 5%
Property Damage*
  • Cooking equipment 40%
  • Electrical/Lighting equipment 13%
  • Intentional 10%
  • Heating equipment 7%
  • Smoking Material 5%

*Note: Does not equal 100%; lesser contributors not included.   Source: Encore Fire Protection

Yet, we’re finding an unnerving reaction amongst operators: They are still failing to follow the regulations, guidelines and approved codes of practice in respect to planned preventive maintenance of kitchen extraction systems.

Often, kitchen safety risks jeopardize the building and its staff and guests as part of a misguided effort to reduce building operating costs. Yet recouping from a fire costs significantly more than routine maintenance and management, and risks lives, which are priceless.

At WYG, a Tetra Tech company, we have spent nearly a decade monitoring the recommended guidelines for maintaining kitchen extraction systems that meet approved codes of practice to maintain safety and reliability.

Top 5 Risks to Commercial Kitchens 

The following five items are the most commonly found issues within Kitchen Extraction Systems that need improvement.

  1. Lack of cleaning and maintenance
    • Levels of grease in excess of the recommended micron level
    • Systems not cleaned frequently enough
  2. Poor / inadequate access to ductwork sections
    • No access doors present
    • Poor standard or quantity of access door
  3. Inaccessible access
    • No safe means of accessing ductwork or access panels
    • Access doors / ductwork that has been blocked by other services
  4. Lack of expertise
    • Maintenance companies not providing due diligence to clients
    • Sub-standard maintenance being provided for a quick sale
  5. Poor responsibility
    • Clients are not accepting responsibility to ensure systems are maintained to the required standards
    • Contractors are not taking responsibility to maintaining the recommended standard and standing ground with clients

Take the First Step Toward Increased Commercial Kitchen Safety and Compliance

When you partner with an independent, professional organisation such as WYG, you will receive an increased level of expertise and commitment. In the past decade of providing reviews and audits of kitchen extraction systems, we have helped clients avoid kitchen fire due to poor maintenance.

We will review your unique system for compliance and provide actionable steps to assist in increasing the standard of your system and therefore reducing the risk of fire. This will be in cooperation with cleaning and maintenance companies, insurance organisations and, of course, such associations such as Building Engineering Services Association (BESA), National Association of Air Duct Specialists (NAADUK), and Fire Protection Agency (FPA), to name a few.


Here are examples of some of our past findings:

Our professional consultants, auditors and surveyors are experts in applying compliance and can take control of your entire asset portfolio which will:

  • Provide compliance to regulations and minimize fire risks
  • Give you detailed, recognised proof that the ventilation system in your building is safe and well maintained
  • Support insurance policies
  • Take care of the safety and wellbeing of the users of your building.

Learn more or contact me directly for further guidance and support. Here’s to safer buildings and better operation!


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Tetra Tech Compliance Expert to Present at Upcoming AIAG Conference

Project manager Mayrie Eckermann will be presenting at the AIAG 2019 IMDS and Product Chemical Compliance Conference, October 16–17.

Eckermann’s presentation, entitled “Data Quality Improvements,” will dive into an issue plaguing manufacturers and their suppliers: collecting and improving the quality of their data information — and acceptance of streamlined IMDS submission.

Specifically, the presentation will take audience members through Eckermann’s groundbreaking five “CLIMB” strategies that help address any data shortcomings and place organizations on the right track for high-quality data collection and management, using IMDS.

“The quantities of data that manufacturers must collect and make usable is massive. When managing their internal data, along with the uncertainty of the data quality suppliers send, it is no wonder this continues to be an issue. With constant updates to industry regulations and customer requirements, quality of data is more important than ever,” Eckermann said. “By touching on this topic, I hope to provide the industry some actionable tools to remain at the forefront of compliance.”

Her presentation will be held on Thursday, October 17, at 10:30 a.m. Eastern Time at the Mint at Michigan First Conference Center in Lathrup Village, Michigan.

Eckermann has 18 years of product compliance experience and has conducted hundreds of IMDS and Product Compliant related trainings. She is the lead project manager for 40 active product compliant projects at Tetra Tech, utilizing a personalized approach to turnkey and process-based solutions for her clients.

The 2019 AIAG conference theme is “Beyond ELV: The Expanding Requirements for Compliance Reporting,” which along with Eckermann’s insights will include information on what you will need to meet upcoming and ever-changing requirements.

For more information or to register for the conference before the October 9 deadline, visit the AIAG registration page here 


Sign Up for Data Quality Strategies