SUBSTANCES UPDATE
Is the SCIP Database Going Away? The Proposed Repeal, the REACH Article 33 Duties That Stay, and Substance Data in the DPP
The SCIP database may go away, but not by law today: on 10 December 2025 the Commission proposed to end suppliers’ duty to notify ECHA’s SCIP database (COM(2025) 986). It is not adopted, and the text gives no end date. REACH Article 33 stays: you still inform business customers and, on request, consumers.
Three duties, three legal routes
- SCIP notificationWFD Art. 9(1)Proposed to end
- REACH Article 33Customers, consumersStays
- ESPR passport dataArts. 4 and 7Needs delegated act
Repeal is a proposal only
What you need to know
- 1
The SCIP duty still applies.
Since 5 January 2021, suppliers of articles with a Candidate List substance above 0.1 % weight by weight must give ECHA the Article 33(1) information (Waste Framework Directive, Art. 9(1), point (i)); on the guide’s reading, via national law. ECHA excludes suppliers serving only consumers. §1
- 2
REACH Article 33 is untouched.
Business recipients get enough information for safe use, at least the substance name; a consumer who asks gets it free of charge within 45 days. The proposal does not amend REACH. §2
- 3
The 0.1 % test is per article.
The Court of Justice (Case C-106/14) measures the threshold against each article in a product. §2
- 4
No end date in the text.
The end is a placeholder for entry into force, with 24 months (in square brackets) to transpose. On the guide’s reading, it would end through national law, not on one EU-wide day. §3
- 5
Still a proposal, and open.
The Council mandate (24 June 2026) keeps the repeal; some amendments tabled in Parliament’s environment committee would delete it; they are individual members’ proposals, not Parliament’s position. The ENVI vote is planned for early November 2026. §4
- 6
The DPP is not SCIP’s legal successor.
ESPR asks for substance-of-concern data only once a delegated act sets it (Arts. 4 and 7). The proposal does not name the passport in any Article or recital; Commission statements are intentions. §5
- 7
A possible gap.
If the repeal is adopted as proposed, notifications could stop in a Member State before a textile act requires passport substance data, leaving REACH Article 33 (plus Article 7(2) where it applies) as the main EU-wide duty on substance information. Our assessment, not an EU statement. §5
What to do now
Keep notifying SCIP where it applies.
The proposal is not law. §6
Keep the Article 33 process running.
Consumer requests answered within 45 days. §6
Keep the substance data per article.
Name, location, concentration, safe use. §6
When does this apply to fashion?
Today
No textile act
No textile delegated act exists yet.
Indicative
Q3–Q4 2027
Commission pages (Q4 2027 on the textile page). Not fixed.
Application
Around 2029
About 18 months after the delegated act enters into force, save in duly justified cases (ESPR Art. 4(4)), on the planning dates.
Status of the guide: 20 October 2026. Based on Directive 2008/98/EC, Article 9; REACH Article 33; ESPR Articles 4(4) and 7; COM(2025) 986. A simplified summary: the full guide below and the EU texts are authoritative. Not legal advice.
Everything below is the complete, sourced guide. ↑ Back to the short version
SCIP is the ECHA database in which suppliers of articles that contain a substance of very high concern from the REACH Candidate List above 0.1 % weight by weight have had to submit information since 5 January 2021. On 10 December 2025 the Commission proposed to end that duty. This is a proposal, not law: on 20 October 2026 the European Parliament's procedure file still read "Awaiting committee decision", and the Council's negotiating mandate had been agreed in Coreper on 24 June 2026. The proposal does not touch REACH Article 33, the separate duty to pass the same kind of information to business customers and, on request, to consumers. That duty stays.
This guide keeps three questions apart. First, what the proposal would change in Article 9 of the Waste Framework Directive, and why we give no end date for SCIP: the text does not contain one. Second, what stays under REACH Article 33 whatever happens to SCIP. Third, how the same substance data relates to the Digital Product Passport (DPP): ESPR asks for substance-of-concern information in a passport only once a product-specific delegated act says so, and there is no such act for textiles yet. For ESPR's definition of substances of concern, see our substances-of-concern guide; for chemical limits that apply now, see our REACH Entry 72 guide and PFAS guide.
Proposal only
COM(2025) 986 of 10 December 2025 would end suppliers' duty to notify ECHA. On 20 October 2026 Parliament's procedure file read "Awaiting committee decision".
Article 33 stays
The proposal amends four directives, not REACH. Information on Candidate List substances for business customers, and for consumers on request within 45 days, is REACH Article 33 (Article 33(1) and (2)).
No end date
The end of the supplier duty is tied to "[date of entry into force of this Directive]", a placeholder, and the Commission text gives Member States 24 months to transpose, also in square brackets. We do not give a calendar date.
1. What SCIP is today, and what it asks of a fashion brand
Article 9(1), point (i), Directive 2008/98/EC (Waste Framework Directive), consolidated version of 16 October 2025
"promote the reduction of the content of hazardous substances in materials and products, without prejudice to harmonised legal requirements concerning those materials and products laid down at Union level, and ensure that any supplier of an article as defined in point 33 of Article 3 of Regulation (EC) No 1907/2006 of the European Parliament and of the Council […] provides the information pursuant to Article 33(1) of that Regulation to the European Chemicals Agency as from 5 January 2021;"
Article 9 is addressed to the Member States: "Member States shall take measures to prevent waste generation. Those measures shall, at least:" On our reading, the supplier duty therefore reaches companies through national law. Directive (EU) 2018/851 replaced Article 9 (Article 1, point 10) and had to be transposed by 5 July 2020 (Article 2(1)). Article 9(2) gives ECHA the database task: "The European Chemicals Agency shall establish a database for the data to be submitted to it pursuant to point (i) of paragraph 1 by 5 January 2020 and maintain it." ECHA must also give access: "The European Chemicals Agency shall provide access to that database to waste treatment operators. It shall also provide access to that database to consumers upon request." The Directive never uses the name SCIP; that is ECHA's name for the database.
What this asks of a brand follows from the trigger, which Article 9(1), point (i), borrows from REACH Article 33(1): an article containing a substance that meets the REACH Article 57 criteria and is identified under Article 59(1), the Candidate List, in a concentration above 0.1 % weight by weight. The Commission's explanatory memorandum describes the duty this way: "The obligation falls on an enterprise that produces, assembles, imports or distributes an article that contains substances of very high concern (SVHCs) on the Candidate List (managed by the European Chemicals Agency) in a concentration above 0.1 % by weight." It describes the content: "The data covers the concentration range and location of the Candidate List substances present in the article, and information that allows its safe use." On our reading the 0.1 % test is applied to each article, not to the weight of the finished product: Article 9(1), point (i), borrows the Article 33(1) trigger, and the Court of Justice's judgment in Case C-106/14 concerns REACH Articles 7(2) and 33 (see section 2). ECHA's SCIP page, read on 20 October 2026, still states that companies supplying such articles "have to submit information on these articles to ECHA, as from 5 January 2021", and it does not mention the proposal.
Suppliers that supply only consumers. REACH Article 33(1) runs to the recipient of an article, and Article 3, point 35 defines the recipient so that it does not include consumers (quoted in section 2). ECHA's page for suppliers of articles (read 20 October 2026) lists EU producers and assemblers, EU importers, EU distributors of articles and other actors placing articles on the market among the suppliers that need to provide information, and says: "Retailers and other supply chain actors supplying articles directly and exclusively to consumers are not covered by the obligation to provide information to the SCIP database." Whether your company is within that sentence depends on whom it supplies, so check it against your own supply chain. Consumers can still ask for information under REACH Article 33(2) (section 2).
Why the Commission wants to end it. The memorandum reports stakeholder concerns that little use is made of the database, perhaps because the data are too complex to be meaningful for most people, and lists duplication of REACH Article 33(1) among the criticisms. Recital (5) of the proposal adds disproportionally high costs, especially for IT investment, and low compliance and enforcement rates. The legislative financial and digital statement gives a figure (section 1.3.3): "Overall, the avoided cost for business is estimated to be EUR 225 million per annum but could be higher in future years." The explanatory memorandum (section 3) gives the same figure for the Waste Framework Directive as a whole ("EUR 225 million for the Waste Framework Directive"), while the Commission's questions and answers (QANDA/25/2998) give the saving from repealing the SCIP database as "at least €225 million per year". In each place it is the Commission's estimate of savings for business as a whole, not a cost per company.
2. What stays: REACH Article 33 is a different legal basis
Article 33(1), Regulation (EC) No 1907/2006 (REACH), consolidated version of 22 June 2026
"Any supplier of an article containing a substance meeting the criteria in Article 57 and identified in accordance with Article 59(1) in a concentration above 0,1 % weight by weight (w/w) shall provide the recipient of the article with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance."
Article 33(2) gives consumers the same right on request: "On request by a consumer any supplier of an article containing a substance meeting the criteria in Article 57 and identified in accordance with Article 59(1) in a concentration above 0,1 % weight by weight (w/w) shall provide the consumer with sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance." The clock is in the same paragraph: "The relevant information shall be provided, free of charge, within 45 days of receipt of the request." Article 33(1) has no time limit in its text.
The two duties differ in kind. REACH is a Regulation and applies directly in every Member State. Article 33 runs from supplier to customer and to consumer; it involves no submission to ECHA and no database. Who must act is wide: "supplier of an article" means "any producer or importer of an article, distributor or other actor in the supply chain placing an article on the market" (Article 3, point 33), so a brand, an importer and a wholesaler are each covered. The recipient who must be informed is "an industrial or professional user, or a distributor, being supplied with an article but does not include consumers" (Article 3, point 35). In Case C-106/14 (judgment of 10 September 2015) the Court of Justice ruled that for a product made up of several articles the threshold is measured against each article. The operative part says the supplier must inform the recipient and, on request, the consumer where an article contains the substance "in a concentration above 0.1% weight by weight of that article, to inform the recipient and, on request, the consumer, of the presence of that substance by providing them, as a minimum, with the name of the substance in question". Which parts of a garment or shoe are separate articles is a question under the REACH definition; our substances-of-concern guide explains how the REACH test differs from the ESPR product test.
The proposal does not change any of this. It amends four directives and not REACH, and REACH appears in it only as a cross-reference: the new point (ia) of Article 9(1) refers to "the information pursuant to Article 33(1) of that Regulation". The memorandum lists duplication of REACH Article 33(1) among the criticisms of the database, which suggests that the Commission treats Article 33 as the baseline that remains. REACH Article 7(2), the separate notification to ECHA by producers and importers of articles, is outside the proposal as well; it applies only where, among other conditions, "the substance is present in those articles in quantities totalling over one tonne per producer or importer per year". The Commission's REACH page still says "The Commission is currently revising the REACH Regulation", but it was last modified on 28 November 2023. On 27 April 2026 Commissioner Jessika Roswall told the ENVI committee: "we have come to the conclusion to not open REACH at this point" (speech SPEECH/26/897), and a Council note of 12 June 2026 (ST 10294/26) records that the Commission indicated in statements made in April 2026 that "the legislative revision of REACH initially foreseen in the Chemicals Strategy for Sustainability would not be pursued in the current mandate". We found no Commission proposal for the general revision of REACH foreseen in the Chemicals Strategy for Sustainability in the Publications Office records on 20 October 2026. The two 2025 Commission proposals we found that amend other REACH provisions, COM(2025) 386 (on the European Chemicals Agency) and COM(2025) 822 (on defence readiness), do not, as proposed, amend Article 33, so Article 33 reads today as quoted.
3. What the Commission proposal changes, what it leaves alone, and why there is no end date
The Commission adopted the proposal on 10 December 2025 as COM(2025) 986 final (procedure 2025/0394(COD)), part of its environmental Omnibus VIII simplification package. It would amend Directives 2008/98/EC, 2010/75/EU, (EU) 2015/2193 and (EU) 2024/1785 "as regards simplification of some requirements and reduction of administrative burden". The word SCIP appears in the explanatory memorandum and in the legislative financial and digital statement, but in no recital and no Article; recital (5) opens with "The database established pursuant to Article 9(2) of Directive 2008/98/EC". The change to the supplier duty is in Article 1, point 2.
Article 1, point 2, COM(2025) 986 final (proposed Article 9(1), point (ia), and Article 9(2) of Directive 2008/98/EC)
"(ia) ensure that any supplier of an article as defined in Article 3, point 33 of Regulation (EC) No 1907/2006 […] provides the information pursuant to Article 33(1) of that Regulation to the European Chemicals Agency from 5 January 2021 until [date of entry into force of this Directive];" And for paragraph 2: "The European Chemicals Agency shall maintain the data submitted to it pursuant to paragraph 1, point (ia)."
| Provision | Today | Under the Commission proposal (not law) |
|---|---|---|
| Waste Framework Directive, Article 9(1), point (i) | One point combines the hazardous-substances clause and the supplier duty to give ECHA the Article 33(1) information "as from 5 January 2021". | Replaced (Article 1, point 2(a)(i)). Only the clause "promote the reduction of the content of hazardous substances in materials and products, without prejudice to harmonised legal requirements concerning those materials and products laid down at Union level" stays in point (i). |
| Article 9(1), new point (ia) | Does not exist. | Inserted (Article 1, point 2(a)(ii)): suppliers give ECHA the information "from 5 January 2021 until [date of entry into force of this Directive]". The Council mandate of 24 June 2026 keeps point (ia) and this end-date mechanism. |
| Article 9(2) | ECHA must establish and maintain the database and give access to waste treatment operators and, on request, to consumers. | Replaced (Article 1, point 2(b)): ECHA "shall maintain the data submitted to it pursuant to paragraph 1, point (ia)". The Commission text has no sentence on access. The Council mandate adds a duty to make the data public: "The European Chemicals Agency shall maintain and make publicly available the data submitted to it pursuant to paragraph 1, point (ia)." The digital section of the financial statement (section 4) lists a SCIP archive with public online access maintained, but that statement is not part of the Articles. |
| Recital (5) | No equivalent. | "Hence, the obligation for suppliers to submit data to the database should not be continued. Data that has already been reported should continue to be maintained by the European Chemicals Agency." |
| Transposition and entry into force (Articles 5(1) and 6) | Not applicable. | Member States bring national provisions into force within "24 months from date of entry into force of this Directive", a figure the Commission text sets in square brackets. The Directive enters into force "on the twentieth day following that of its publication in the Official Journal of the European Union". There is no separate date of application and no transitional provision for notifications in progress. |
| REACH Articles 7(2) and 33; ESPR | In force. | Not amended. The proposal does not amend REACH or ESPR. |
Why we give no end date. The end of the duty is not a date in the text. Point (ia) ends it at "[date of entry into force of this Directive]", a placeholder; Article 5(1) gives Member States 24 months, in square brackets as well, to bring national provisions into force; and Article 9(1) is a duty on the Member States, not directly on suppliers. The proposal does not say what applies between entry into force and national transposition, for example whether ECHA keeps accepting submissions. On our reading, then, the duty would end for suppliers in each Member State through that State's own transposing law, within the limits of the final text, and not on one EU-wide day. The Council mandate leaves this mechanism unchanged.
Where the Commission says what. The sentence that the repeal reduces administrative burden is not in the explanatory memorandum. It is in the legislative financial and digital statement at the end of the document, section 1.5.2 ("Added value of EU involvement"): "The repeal of the SCIP database will reduce administrative burden across the Union linked to notification obligations." The same statement lists the aim in section 1.3.2 as the "Repeal of the obligation to notify substances of very high concern in products to the SCIP database".
A side point for textile EPR. The same proposal would also amend Article 8a(1), point (c), the general minimum requirements for extended producer responsibility schemes, so that producers, or their authorised representatives for EPR, are required to report "at a maximum frequency of once every 12 months, for each full preceding calendar year" (Article 1, point 1). Article 22a(1) places the textile EPR scheme "in accordance with Articles 8 and 8a", so the cap would reach textile reporting if it survives. It is not certain to: the Council mandate of 24 June 2026 deletes Article 1, point 1, and the point is unrelated to SCIP. How textile EPR works and how reporting differs between countries is covered in our textile EPR guide and country comparison of textile EPR.
4. Where the proposal stands on 20 October 2026
A directive proposed under the ordinary legislative procedure becomes law only when Parliament and the Council agree on the same text. Nothing has been adopted: the Publications Office records searched on 20 October 2026 show the proposal, and a corrigendum to its Annex 1 for the German-language version that does not concern SCIP, but no adopted act. The table gives each step as shown by the cited source on that date.
| Step | Status on 20 October 2026 | Source |
|---|---|---|
| Commission proposal | Adopted and published on 10 December 2025 as COM(2025) 986 final. | CELEX 52025PC0986; Legislative Observatory (OEIL). |
| Council | Negotiating mandate agreed in Coreper on 24 June 2026 and published as document ST 11112/26 of 25 June 2026. It keeps the repeal and adds "make publicly available" to Article 9(2). The EU Law Tracker lists Council deliberations on 22 September and 13 October 2026. The Council's press release does not mention SCIP; it says the Irish presidency will enter negotiations with Parliament "once both co-legislators adopt their positions". | Council ST 11112/26; Council press release of 24 June 2026; EU Law Tracker. |
| Parliament: committee work | OEIL stage: "Awaiting committee decision". Lead committee ENVI; rapporteur Susana Solís Pérez (EPP), appointed 24 March 2026. Draft report PE787.998 (16 June 2026); ITRE opinion PE787.849 (14 July 2026); AGRI opinion PE787.938 (2 September 2026). Of the draft report's amendments, the only one that touches SCIP is to recital (5), keeping the repeal and strengthening its justification; the draft report does not amend the Articles on SCIP. | OEIL 2025/0394(COD); draft report PE787.998. |
| Parliament: amendments | Amendments tabled in committee: PE790.834 (20 July 2026) and PE791.123 (28 July 2026). In PE790.834, amendments 160 and 161 would delete the proposed point (ia); the justification of amendment 160 says that ending the obligation to pass the information to ECHA would be irresponsible. Amendment 167 would reinstate, with slight rewording, the three current sentences of Article 9(2) on the database and on access for waste treatment operators and consumers, and add a sentence requiring ECHA to ensure by 1 January 2028 that the database facilitates clear identification by consumers of the articles concerned and provides tools that facilitate aggregation of the data for waste treatment operators. Amendments are proposals by individual members, not Parliament's position. This row describes three of the amendments in PE790.834 that touch the SCIP provisions (recital (5) and Article 9(1) and (2) of the Directive). Others would, for example, rewrite point (ia) so that the supplier duty to provide the information has no end date, unless the supplier provides it through a digital product passport to the web portal established under Article 14 of Regulation (EU) 2024/1781 (amendment 162), or say in recital (5) that the obligation should be maintained until an alternative system, such as the Digital Product Passport, that ensures at least an equivalent level of information on substances of very high concern in articles is fully operational and accessible to waste operators and other relevant stakeholders (amendment 70). PE791.123 does not use the word SCIP, but amendment 414 would require Member States to transpose Article 1, point 2(a) of the proposal (the change to Article 9(1) of the Directive) within six months of entry into force instead of 24 months, and amendment 416 would extend the transposition period for the whole Directive to 36 months. | PE790.834; PE791.123; OEIL. |
| Parliament: next steps | The vote in ENVI is "currently planned for early November 2026" (Legislative Train, information as of 20 September 2026). OEIL forecasts an indicative first-reading plenary sitting on 14 December 2026. No committee vote and no plenary position is recorded. | Legislative Train; OEIL. |
| Trilogue and adoption | No trilogue is recorded and no adopted act exists. The Council's press release says the institutions' "One Europe, One Market" roadmap of 24 April 2026 sets the objective of concluding all simplification packages by the end of 2027; we do not read that as a date for this file. | Council press release of 24 June 2026; Publications Office records. |
| Committee of the Regions | Its opinion CDR 0953/2026 (OEIL date 7 May 2026) "warns against the announcement to repeal or suspend the SCIP database or associated hazardous substance information obligations unless and until a fully functional and interoperable digital product passport (DPP) system providing at least the same level of traceability, accessibility and enforcement capacity is operational across the EU". An advisory opinion. | CoR opinion CDR 0953/2026; OEIL. |
| ECHA | ECHA's SCIP page still describes the notification as an obligation and does not mention the proposal. Its programming document for 2026–2028 (11 December 2025) says: "We will begin scaling down related activities on SCIP from 2026. This will be done gradually over time as a result of the reduced resources expected from the end of 2026 and ongoing uncertainty regarding long-term resourcing and the future of SCIP." | echa.europa.eu/scip (read 20 October 2026); ECHA Single Programming Document 2026–2028. |
A proposal can change at each step. Some amendments tabled in Parliament would delete point (ia), at least one would rewrite it so that the supplier duty has no end date, with an exemption for information provided through a digital product passport, and the justification of one of the deleting amendments says that ending the obligation would be irresponsible, so the final text could keep the duty, shorten it, or change the wording on public access. How the tabled amendments would combine is not settled until the committee votes. Until an act is adopted and applies in your Member State, the existing duty in section 1 is the law.
5. Substance data and the DPP: the same kind of information, a different legal route
Article 7(5), Regulation (EU) 2024/1781 (ESPR)
"Unless otherwise provided for under paragraph 6, point (b), the information requirements shall make it possible to track the substances of concern, throughout the life cycle of the products concerned, unless such tracking is already possible pursuant to information requirements laid down in another delegated act adopted pursuant to Article 4 covering the products concerned, and shall include at least the following: (a) the name or numerical code of the substances of concern present in the product […]; (b) the location of the substances of concern within the product; (c) the concentration, maximum concentration or concentration range of the substances of concern, at the level of the product, its relevant components, or spare parts; (d) relevant instructions for the safe use of the product; (e) information relevant for disassembly, preparation for reuse, reuse, recycling and the environmentally sound management of the product at end-of-life"
That is the same kind of data SCIP collects: identity, location, concentration range and safe-use information. The overlap is in the data, not in the legal duty. ESPR differs in four ways. First, it applies to a product group only once a delegated act sets the information requirements (Articles 4 and 7(1)). Second, its trigger is wider: a substance of concern under Article 2(27) includes Candidate List substances in point (a), and also substances in certain CLP hazard classes, substances regulated under the POPs Regulation and substances that negatively affect reuse and recycling. Third, the Commission "may, where appropriate for the product group concerned, set thresholds for when the information requirement regarding substances of concern is to apply" (Article 7(5)), and, where relevant, delegated acts provide duly justified exemptions, but "substances of concern within the meaning of Article 2(27), point (a), shall not be exempted if they are present in products, their relevant components or spare parts in a concentration above 0,1 % weight by weight" (Article 7(6), point (b)). Fourth, the data goes into the passport: "Where a digital product passport is available, the required information shall be provided therein" (Article 7(7)). For ESPR's full wording on substances of concern, see our substances-of-concern guide. Who may see which passport data is a separate question, covered in our access-rights guide.
The DPP is not SCIP's legal successor. The proposal never names the passport in an Article or recital, and it does not mention ESPR at all. The only places where it mentions the passport are two sentences. In the explanatory memorandum: "The use of digital product passports and in the future more comprehensive product labels will further limit the future additional benefit of the database." In the financial statement, section 1.5.2: "The use of digital product passports and in the future more comprehensive product labels will further facilitate the availability of data in a useful and harmonised approach." On the ESPR side, SCIP appears once, in recital (34), which says: "Where feasible, the Commission should also link the digital product passport to existing Union databases and tools such as the European Product Registry for Energy Labelling (EPREL) or the database for information on Substances of Concern In articles, as such or in complex objects (Products) (SCIP)." That is an invitation to link systems, in a recital, not a transfer of the SCIP duty.
The Commission has gone further in communications. Its press release of 10 December 2025 says SCIP's "functions will be replaced with more effective digital solutions such as the Digital Product Passport and implementation of the One Substance One Assessment package". Its questions and answers say that EU chemicals legislation, in particular that package, "and the digital product passport will progressively fulfil the envisaged role of the database, while avoiding duplication". Its Communication of the same day adds: "When designing the digital product passport for products, the Commission will include data about substances of very high concern in its scope." These are statements of intention. A related act is Regulation (EU) 2025/2455 of 26 November 2025 on a common data platform on chemicals, which recalls the one substance, one assessment approach in its first recital. Its Article 11(1) tasks ECHA to "establish and manage, as part of the common data platform, a database containing data on chemicals in articles or products generated or submitted as part of the implementation of Union legal acts listed in Annex V", and Annex V lists three acts, among them Directive 2008/98/EC and ESPR. The Regulation does not mention SCIP, and the proposal does not say whether or how existing SCIP data would be carried over into that database or into a passport; it says only that ECHA keeps the data already reported.
On our reading, the Commission's ESPR FAQ line has been overtaken by the proposal. The ESPR FAQ (1st edition, dated 25 September 2024, question 121) says: "The Commission aims at a progressive alignment and integration of SCIP with the DPP as far as technically possible, to avoid the duplication of requirements for products and substances covered by both ESPR and SCIP." It adds that the scope of reporting "both in terms of substances and product groups covered is different". That was an aim stated in 2024, in a document whose cover says "it reflects the views only of the authors". It is still the edition linked from the Commission's ESPR implementation page on 20 October 2026, but the Commission's December 2025 proposal does not align the two systems and does not mention ESPR: it proposes to stop new SCIP submissions. The Commission's current DPP web pages do not mention SCIP; its DPP FAQ says: "The information on substances of concern present in a product will be included in the DPP if a DPP is required for the product." (web FAQ, last modified 30 September 2026).
No textile delegated act exists. The Have your say initiative 16116 on ecodesign requirements for apparel textiles was still at the planning stage on 20 October 2026, with no draft published; the adoption field of that record still shows Q1 2027 and has not been updated since the record was created on 12 December 2025, so we follow the Commission's pages. The Commission's textile page (last modified 7 August 2026) gives the indicative timeline as Q4 2027 for the "Planned adoption of the ESPR Delegated Act for textiles", and its DPP page (last modified 22 October 2026) shows Q3–Q4 2027 for the delegated acts on textiles, aluminium and tyres, with "a transition period of at least 18 months" after adoption. ESPR Article 4(4) sets the default: the date of application "shall not be earlier than 18 months from its entry into force, except in duly justified cases for the whole act or for some specific requirements, or except in cases of partial repeal or amendment of delegated acts, where an earlier date of application may be set". On those planning dates, requirements for textiles would apply around 2029. Footwear is a separate question. Section 2.2.3 of the Commission's working plan (COM(2025) 187), headed "Products not included in the first working plan", states: "Footwear is in a separate product category from textiles due to the distinct use of materials, product functionality and supply chains." and provides only for a study that "will be completed by the end of 2027". Footwear is therefore outside the first working plan, and there is no ESPR timeline for it yet; see our footwear guide and the DPP master timeline.
Our assessment — a possible gap, not an EU statement
If the repeal is adopted as proposed, suppliers could stop notifying ECHA in a Member State before any textile delegated act requires substance data in a passport. In that interval the main EU-wide duty to pass Candidate List information on clothing along the supply chain would be REACH Article 33 (alongside the notification to ECHA under Article 7(2), where its conditions are met): information to recipients, and to consumers on request. The two timelines are both open, since neither the end of national SCIP duties nor the textile act has a fixed date, so they could overlap in either direction. Read this as a risk to plan for, not a prediction.
6. What to do now
Nothing in the proposal tells a brand to change anything today. The points below are our recommendations for a period in which one duty may end, another stays and a third is still to be written. The recommendations themselves are not legal duties; where a row restates an existing duty (the first two rows), the duty comes from the provision named in the right-hand column.
| Step | What we recommend | Why |
|---|---|---|
| Keep notifying SCIP | Where the duty applies to you, keep submitting notifications for articles you place on the EU market that contain a Candidate List substance above 0.1 % weight by weight, and keep the process documented. Do not treat the proposal as law. Once an act is adopted, check your Member State's transposing law for the end of the duty. | Waste Framework Directive Article 9(1), point (i), as consolidated on 16 October 2025. COM(2025) 986 is not adopted and has no transitional rule for the supplier duty. |
| Keep the Article 33 process running | Make sure business customers that receive your articles also receive the substance information. Make sure consumer requests reach someone who can answer within 45 days, free of charge, and name an owner for them. | REACH Article 33(1) and (2); not touched by the proposal. |
| Test per article | Run the 0.1 % check for each article rather than for the finished product, and record the result per article. | Case C-106/14, operative part. |
| Keep the SVHC dataset | Keep, per article: the substance name and identifiers (such as EC and CAS numbers), where it sits in the article, its concentration or concentration range, and the safe-use information. Store it so that it can serve Article 33 answers now and a passport later. | REACH Article 33(1) (at least the name); ESPR Article 7(5), points (a) to (d); the SCIP data content as the Commission describes it. |
| Keep your own record | Keep a copy of every SCIP submission and of the supplier data behind it. | The Commission text would have ECHA maintain the data but has no sentence on access; the Council mandate adds public availability. The final wording is open. |
| Avoid SCIP-only tooling | Put new effort into the data model, not into formats that serve only SCIP. The textile delegated act will decide which substances, thresholds and exemptions apply, and ESPR's definition is wider than the Candidate List. | ESPR Articles 2(27), 7(5) and 7(6); no textile delegated act yet. |
| Plan for a gap | If you sell textile products, assume that for some period REACH Article 33 may be the main EU-wide duty on substance information (Article 7(2) applies as well where its conditions are met). Check that supplier contracts give you the data you need for Article 33 answers. | Our assessment in section 5. |
| Watch the dates | Follow the ENVI vote (planned for early November 2026), the plenary (indicative 14 December 2026), any trilogue, the text in the Official Journal, your national transposing law and Have your say initiative 16116 for the textile act. See also our readiness checklist. | Section 4 sources. |
DPP AUDIT
Know which of your articles carry Candidate List substances before the rules change.
We review your product and supplier substance data against REACH Article 33 and ESPR's substance-of-concern requirements, so that one dataset covers both. Under NDA.
Start Your DPP AuditFrequently asked questions
Is the SCIP database going away?
Do we still have to submit information to SCIP today?
If SCIP ends, do we still have to tell customers about hazardous substances in our products?
On what date would the SCIP duty end?
Will the Digital Product Passport replace SCIP?
Should we stop collecting SVHC data for our products?
Sources
- ProposalProposal for a Directive of the European Parliament and of the Council amending Directives 2008/98/EC, 2010/75/EU, (EU) 2015/2193 and (EU) 2024/1785 of the European Parliament and of the Council as regards simplification of some requirements and reduction of administrative burden, COM(2025) 986 final, Brussels, 10.12.2025, procedure 2025/0394(COD). English text of the Commission proposal: Article 1, points 1 and 2; Articles 5 and 6; recital (5); explanatory memorandum, section 1 (Repeal of the SCIP database) and section 3 (Regulatory fitness and simplification); legislative financial and digital statement, sections 1.3.2, 1.3.3, 1.5.2 and 4. A proposal, not law. CELEX 52025PC0986 ↗
- CouncilCouncil of the European Union, document ST 11112/26 of 25.6.2026, outcome of proceedings: mandate for negotiations with the European Parliament, as agreed by the Permanent Representatives Committee on 24 June 2026. ST 11112/26 ↗ · Council press release of 24.6.2026 (updated 2.7.2026), Simplification: Council agrees negotiating stance to simplify and streamline environmental rules. Council ↗ · EU Law Tracker, procedure 2025/0394(COD). EU Law Tracker ↗
- ParliamentEuropean Parliament, Legislative Observatory, procedure 2025/0394(COD) (accessed 20.10.2026). OEIL ↗ · Draft report PE787.998 (16.6.2026) ↗ · Amendments PE790.834 (20.7.2026) ↗ · Amendments PE791.123 (28.7.2026) ↗ · Legislative Train Schedule, information updated as of 20.9.2026. Legislative Train ↗
- Waste Framework DirectiveDirective 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and repealing certain Directives, consolidated version of 16.10.2025: Articles 8a, 9 and 22a. Directive (EU) 2018/851 of 30 May 2018 (OJ L 150, 14.6.2018), Articles 1(10) and 2(1). The consolidated version has no legal effect; the authentic text is in the Official Journal. CELEX 02008L0098-20251016 ↗ · CELEX 32018L0851 ↗
- REACHRegulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), consolidated version of 22.6.2026: Articles 3, 7, 33, 57 and 59. The consolidated version has no legal effect; the authentic text is in the Official Journal. CELEX 02006R1907-20260622 ↗ · Commission proposals checked for amendments to REACH: COM(2025) 386 final of 8.7.2025, Article 48 (CELEX 52025PC0386 ↗), and COM(2025) 822 final of 17.6.2025, Article 1 (CELEX 52025PC0822 ↗).
- Court of JusticeJudgment of the Court (Third Chamber) of 10 September 2015, Case C-106/14, Fédération des entreprises du commerce et de la distribution (FCD) and Fédération des magasins de bricolage et de l'aménagement de la maison (FMB) v Ministre de l'Écologie, du Développement durable et de l'Énergie, operative part. CELEX 62014CJ0106 ↗
- ESPRRegulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products, amending Directive (EU) 2020/1828 and Regulation (EU) 2023/1542 and repealing Directive 2009/125/EC. Recital 34; Articles 2(27), 4(4), 7(1) and 7(5) to (7). Read in the Official Journal version; the Regulation has not been amended; the corrigenda published up to 20.10.2026 were checked and none affects the passages cited. CELEX 32024R1781 ↗
- Commission statementsEuropean Commission, press release IP/25/2997 of 10.12.2025 (point 3). IP/25/2997 ↗ · Questions and answers QANDA/25/2998. QANDA/25/2998 ↗ · Communication COM(2025) 980 final, Simplifying for sustainable competitiveness. CELEX 52025DC0980 ↗
- Commission DPP pagesEuropean Commission, Digital Product Passport page (last modified 22.10.2026). DPP page ↗ · Textile apparel page (last modified 7.8.2026). Textile page ↗ · DPP FAQs (last modified 30.9.2026). FAQs ↗ · ESPR FAQ, 1st edition, 25.9.2024, question 121. ESPR FAQ ↗ · Have your say, initiative 16116. Have your say ↗
- ESPR working planCommunication from the Commission, Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030, COM(2025) 187 final of 16.4.2025, section 2.2.3. CELEX 52025DC0187 ↗
- Chemicals dataRegulation (EU) 2025/2455 of the European Parliament and of the Council of 26 November 2025 establishing a common data platform on chemicals, laying down rules to ensure that the data contained in it are findable, accessible, interoperable and reusable and establishing a monitoring and outlook framework for chemicals (OJ L, 12.12.2025): recital 1, Article 11(1), Annex V. CELEX 32025R2455 ↗ · European Commission, REACH Regulation page (last modified 28.11.2023). REACH page ↗ · European Commission, address by Commissioner Roswall at a structured dialogue with the ENVI committee, Brussels, 27.4.2026, SPEECH/26/897. SPEECH/26/897 ↗ · Council of the European Union, document ST 10294/26 of 12.6.2026, REACH Regulation: the way forward, exchange of views. ST 10294/26 ↗
- ECHAEuropean Chemicals Agency, SCIP page (read 20.10.2026). ECHA SCIP ↗ · Suppliers of articles page (read 20.10.2026). ECHA suppliers ↗ · Single Programming Document 2026–2028 (11.12.2025). ECHA SPD ↗
- Committee of the RegionsEuropean Committee of the Regions, opinion CDR 0953/2026 on the environmental omnibus package, adopted at its plenary session of 6-7 May 2026 (advisory). CoR opinion ↗
EU legal texts were read in these versions: the Waste Framework Directive and REACH as consolidated (16.10.2025 and 22.6.2026), Directive (EU) 2018/851, ESPR, Regulation (EU) 2025/2455 and the Court of Justice judgment in their Official Journal versions, and the Commission proposal in its published English text, all from the EU Publications Office (EUR-Lex); the Publications Office records were searched on 20.10.2026 and showed no adopted act on the proposal. The Council, European Parliament, ECHA and Commission web pages and documents were accessed on 20.10.2026; where a site blocks automated download, the pages were read in a browser and the passages quoted here were copied from the page. This is general information, not legal, financial or investment advice.