As of January 5th, 2021, European Union manufacturers, assemblers, distributors, and importers of products into the EU must adhere to the Substances of Concern in Products (SCIP) database reporting requirements as established by the European Chemicals Agency (ECHA). SCIP is a database established and maintained by ECHA under the Waste Framework Directive (WFD) 2008/98/EC. Both the EU WFD and the SCIP database are additions to current reporting requirements mandated by the Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) regulation. Generally, the companies that must comply with REACH reporting requirements are also within the scope of the EU WFD and SCIP database reporting requirements.
What is the purpose of the SCIP database?
The SCIP database serves as a catalog of potentially harmful substances in products manufactured, distributed, or imported within the 21 EU member states. The database is intended to help waste operators sort and recycle articles containing Substances of Very High Concern (SVHCs) and inform consumers on how to use and dispose of such articles properly.
The purpose of the SCIP database is to address the negative impact of waste material, including handling, recycling, and disposal, on people’s health and the environment, and to encourage the development of safer alternatives.
Who needs to submit to the SCIP database?
European Union product manufacturers, assemblers, and distributors, as well as importers of products into the EU, must submit information into the SCIP database if their products contain SVHCs above a 0.1% weight over weight (w/w) threshold. The candidate list of SVHCs is based on REACH.
Can SVHCs be declared at the product level for SCIP submissions?
SVHCs can only be declared at the product level if the product is an article of such. Per the SCIP database requirements, substances are to be listed and reported to ECHA at the article level, i.e., the article that is part of the product (or component) but cannot be broken down further; in other words, the smallest article (as such).
The definitions below can be used to determine if your product is considered a complex object or an article of such.
- An article is either an Article as Such or a Complex Object.
- A product is an article, as are its components.
- A complex object is composed of two or more articles.
- An article as such, which must be reported to ECHA, is an article that cannot be dismantled into parts. It can, however, contain several listed materials.
Should a SCIP dossier be submitted manually or automatically with an S2S transfer?
A SCIP dossier can be submitted to ECHA manually using the ECHA Submission Portal or automatically via a system-to-system (S2S) transfer. While the validation process is the same across both submission methods, the S2S option offers the advantage of working with an existing integrative compliance system (which makes it easier to correlate data from diverse sources over several compliance programs).
For manual submission through the ECHA Submission Portal, companies need a valid ECHA account with a designated “Submission Portal Manager” user role.
For automatic submission via the S2S service, companies that offer SCIP database compliance solutions, such as Source Intelligence, can create SCIP notification dossiers from their own systems using the IUCLID SCIP notification format. Once the SCIP notification dossiers have been created, the S2S transfer enables submission to the ECHA Submission Portal.
This resource provided by ECHA offers more information about preparing and submitting SCIP notifications.
How can a SCIP dossier be found in the public database?
Once a dossier is submitted, it is assigned a SCIP number. This number can be used to access a specific company’s dossier in the SCIP database.
How does Source Intelligence's SCIP database compliance solution simplify the submission process?
SCIP database compliance is complex, but our turn-key solution simplifies the process. As your compliance partner, we’ll provide you with the tools needed to collect, aggregate, and submit the required data into a SCIP dossier-ready format.
After submission, we will verify that your dossier has passed validation. If your dossier fails submission, our team will review it to correct failures and resubmit it. We will then track the product for any changes and make submissions to the dossier as applicable. The SCIP number assigned to the product is also available on our platform.
Explore our program to discover how our solution can help streamline the compliance process.
