regulations

SCIP vs DPP: What the Environmental Omnibus Really Changes

The Environmental Omnibus proposes replacing SCIP functions with DPP. What is only a proposal, what still applies, and where the transition risk sits.

5/7/2026 · 12 min read · InfoDPP

The Short Version

The European Commission has proposed that some functions of the SCIP database should in future be replaced by the Digital Product Passport and the broader “One Substance, One Assessment” logic. That is an important signal, but it does not mean SCIP obligations disappeared on 7 May 2026.

SCIP is still the operating ECHA database for information on substances of very high concern in articles.
The Environmental Omnibus is a legislative proposal, not an immediate exemption from reporting.
DPP may become a better access layer for product data, but only if it truly takes over identification, availability, and enforcement functions.
The Committee of the Regions warns that SCIP should not be repealed or suspended before an interoperable DPP operates with comparable traceability.
For companies, the right response is not “stop doing SCIP”, but “structure substance data so it can also live in future DPPs”.

What SCIP Does Today

SCIP is ECHA’s database for information on REACH Candidate List substances in articles, especially where the concentration exceeds 0.1% by weight. Its purpose is not marketing. It is to make sure substance information does not disappear after the first sale of a product, but remains available to waste operators, consumers, and authorities.

In practice, SCIP forces something many companies still do not have in a structured way: a link between product, component, substance, supplier, and source evidence. It is not an elegant product passport, but it is a hard mechanism for preserving chemical information across the lifecycle of an article.

The practical point is simple: until the law changes and ECHA announces a different process, SCIP remains the applicable channel for covered articles.

What the Environmental Omnibus Proposes

The Environmental Omnibus package is part of the Commission’s wider simplification agenda. In its communication, the Commission said that SCIP database functions are to be replaced by the Digital Product Passport and the One Substance, One Assessment approach.

The idea is politically understandable. If, in a few years, a product will already have a DPP with access layers for consumers, authorities, waste operators, and B2B partners, duplicating a separate database for part of the substance data may look inefficient.

The problem is the word “if”. At the start of May 2026, there is not yet a ready horizontal DPP system that replaces all SCIP functions across every relevant product category.

This is a simplification idea with a technical condition, not a magic eraser for chemical obligations overnight.

Where the Warning Comes From

The Committee of the Regions reacted cautiously. In its 7 May 2026 position, it warned that simplification must not weaken environmental protection or shift costs onto cities and regions, especially in waste management.

The most important part concerns SCIP directly. The Committee says that repealing or suspending SCIP and related hazardous-substance obligations should happen only once the DPP is fully functional, interoperable, and able to provide the same level of traceability, accessibility, and enforcement support.

That is not opposition to DPP. It is a warning about the transition gap: do not remove the existing mechanism until the new one provides the same level of protection and enforceability.

Why Replacement Is Not Just Database Migration

SCIP and DPP sound similar because both are digital product-information systems. Their logic is different.

Layer	SCIP today	DPP replacement question
Data scope	REACH Candidate List substances in articles	Will DPP include these data in every relevant category?
Audiences	ECHA, waste, consumers, authorities	Will DPP access roles cover the same needs?
Identification	Article, component, substance, supplier	Will DPP identifiers be precise enough for components?
Enforcement	Reporting channel tied to a legal obligation	Will DPP give authorities an equally stable audit trail?
Timing	Already operating	DPP is being built by category and phase

That is why the sentence “DPP will replace SCIP” is too short. A more accurate version is: DPP may take over some SCIP functions if legal acts, registry, standards, access roles, and enforcement processes are synchronized.

The Awkward Transition Problem

The biggest risk is not that DPP is a bad idea. Quite the opposite: a well-designed passport may provide better context than a separate substance notification because it connects chemistry with product identification, documentation, instructions, repair, and end-of-life handling.

The risk is the transition moment. If SCIP were repealed before DPP works for the relevant categories and stakeholders, some information could fall into a void: no longer in SCIP, not yet in a real DPP.

This matters especially for waste. A waste operator does not need a promise of future interoperability. They need available substance information when the product enters recovery, recycling, or disposal streams.

What This Means for Companies

Companies should not treat the Environmental Omnibus as a reason to stop working on chemical data. It is better read as a signal that SCIP data should become part of a broader product-data architecture.

Do not switch off SCIP on the basis of a press release. The obligation disappears only when the law changes and the responsible institutions describe the new process.
Map substances at component level. DPP may require a better link between chemical data, model, batch, material, and supplier than many current submissions provide.
Keep source evidence close to the record. SVHC data, supplier declarations, material files, and test results should be linked to the product record, not only stored in email threads.
Design access roles. Not everyone should see everything, but waste operators, authorities, and legitimate-interest actors need the right information layer.
Do not confuse DPP readiness with a live DPP obligation. Data and identifiers can be built now, even if the legal details for a product category still await implementing or delegated acts.

What to Watch in 2026

The next months will show whether the simplification proposal is refined in a way that closes the transition gap.

progress on the Environmental Omnibus and any amendment to the Waste Framework Directive
reactions from ECHA and Member States to the idea of replacing SCIP functions
development of the DPP registry, whose first battery version is planned to be operational in July 2026
finalization of JTC 24 DPP standards, because interoperability is not a cosmetic add-on
how sectoral acts define access to chemical and hazardous-substance data

A Useful Way to Think About It

SCIP is today’s chemical-information obligation. DPP is tomorrow’s product infrastructure. The Environmental Omnibus tries to move part of the burden from a separate database into a more integrated system.

That may make sense, but only under one condition: the new system must actually deliver information to the same people, at the same critical moments, with at least the same reliability.

For companies, the best strategy is calm and practical: keep SCIP compliance where it is required, while building substance data so it can later be reused in DPP without rewriting the entire product history.

Official Sources

Building a data model that needs to handle both substances and future DPP? Start free on OriginPass.eu and structure the product record before the rules start overlapping.

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