regulations

SCIP vs DPP: What the Environmental Omnibus Really Changes

COM(2025) 986 proposes removing future SCIP reporting, but SCIP still applies. Here is the legislative status and the role DPP may eventually play.

5/7/2026 · 11 min read · InfoDPP

Editorial update, 3 August 2026: the legal proposal is COM(2025) 986 final, procedure 2025/0394(COD). It would remove the duty to submit new SCIP notifications, but it has not been adopted. The European Parliament procedure is still awaiting a committee decision. SCIP therefore remains the applicable reporting channel for covered articles.

The Short Answer

SCIP has not been replaced by the Digital Product Passport. The Commission has proposed ending new SCIP reporting and preserving access to the existing database. That proposal is still moving through the ordinary legislative procedure.

The Commission’s DPP guidance also makes an important limitation clear: substances of concern are included in a DPP only when EU law requires a DPP for the product concerned and the applicable product rules require those data. DPP is not yet a universal chemical reporting system.

What SCIP Requires Today

SCIP is ECHA’s database for information on Candidate List substances in articles. Companies supplying an article that contains a substance of very high concern above 0.1% by weight may have notification duties under the Waste Framework Directive.

Until the legislation changes, companies should continue using the current ECHA process for articles within scope. A Commission proposal, a committee opinion or the launch of DPP infrastructure does not by itself remove that duty.

ECHA has reported delays in publishing some submitted information. It also states that successfully submitted notifications do not need to be submitted again because of those dissemination delays.

What COM(2025) 986 Proposes

The Environmental Omnibus proposal of 10 December 2025 would amend several environmental laws. For SCIP, it proposes removing the obligation to submit new information to the database. The existing dataset would be archived and remain accessible through public and secure channels.

The Commission expects substance information to continue flowing through REACH communication duties and, where product legislation requires it, through digital labels and DPPs. That is a proposed future architecture, not the current compliance process.

The distinction matters because the proposal does not create a horizontal DPP requirement for every article that currently falls within SCIP. Product coverage, substance thresholds, exemptions and access rights will continue to depend on the relevant EU act.

Current Legislative Status

The proposal follows procedure 2025/0394(COD). As of 3 August 2026, the European Parliament lists it as awaiting a committee decision. The ENVI committee published a draft report on 16 June 2026 and the ITRE committee adopted its opinion on 14 July 2026. The indicative plenary date is 11 November 2026.

Those steps may change the text. They do not suspend current SCIP duties. Formal agreement between Parliament and Council, adoption and publication would still be required before an amendment could take effect.

What the DPP Guidance Clarifies

The Commission’s official DPP FAQ says that substances of concern must be included when a DPP is required for the product and the applicable rules call for that information. The same product-specific rules determine thresholds and exemptions.

Substances and mixtures do not automatically receive an ESPR DPP merely because chemical information exists. A DPP obligation must come from ESPR secondary legislation or another Union act.

The production DPP Registry and its testing environment are operational infrastructure. Their availability does not repeal SCIP and does not prove that every affected product category already has an equivalent substance-traceability route.

Why the Transition Needs Care

SCIP and DPP can hold related information, but they do not currently have the same legal coverage.

Question	SCIP today	Future DPP route
Product coverage	Articles covered by current waste and REACH rules	Products for which a DPP is required by EU law
Substance scope	Candidate List substances above the applicable threshold	Content defined in product-specific legislation
Main users	Authorities, waste professionals, consumers and supply-chain actors	Access roles defined by the applicable passport rules
Status	Existing reporting system	Infrastructure and sector rules introduced in stages

This is why the Committee of the Regions warned against removing SCIP before an interoperable replacement offers comparable traceability, access and enforcement support.

What Companies Should Do Now

Keep current SCIP controls active. Change the reporting process only when an adopted legal act and ECHA instructions require it.
Link substance data to components and product versions. Preserve the relationship between the substance, material, part, supplier declaration and affected model.
Keep the evidence with the record. Supplier declarations, analytical results and classification sources should remain versioned and auditable.
Separate legal scope from technical reuse. The same structured data may support SCIP now and a DPP later, but each output needs its own legal validation.
Design role-based access. Consumers, waste professionals, authorities and business partners may need different views of the same underlying evidence.

What to Watch

The next decisive points are the Parliament and Council positions on procedure 2025/0394(COD), the final treatment of the SCIP archive and any transition date. In October 2026, the JRC Product Bureau also plans consultation on methods for identifying and tracking substances of concern under the ESPR work on electronic displays.

The right readiness approach is therefore stable: comply with SCIP today and structure chemical data so that it can be reused in a future product-specific DPP without losing its evidence trail.

Official Sources

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