2020 has been a busy year for the European Chemicals Agency (ECHA). From February to October, the agency has worked hard on readying its SCIP database, the reporting platform for Substances of Very High Concern (SVHCs) in products manufactured, assembled, imported, or distributed within the EU.
After various test versions, ECHA officially launched SCIP as of October 28, 2020. The submissions platform is no longer a training tool allowing companies to test the system before data is deleted. It is now ready for official submissions.
With the launch came the latest series of format changes. While reporting duties will apply from January 5, 2021, and onward, ECHA encourages impacted businesses to start uploading data as soon as possible.
In 2018, the EU embarked on an ambitious revision of its Waste Framework Directive. At its core is the necessity to work toward a more circular economy and encourage industries to find substitutions for harmful substances and provide information to waste management operators for safer disposal or recycling of SVHCs.
According to the World Economic Forum,
“The circular economy, which promotes the elimination of waste and the continual safe use of natural resources, offers an alternative that can yield up to $4.5 trillion in economic benefits to 2030.”
Be that as it may, reaching full circle cannot happen overnight. In the meantime, the SCIP database will act as both an information platform for waste management companies and consumers, as well as a reminder that harmful chemicals still lurk in the most innocuous products and there is plenty of work yet to be done. Let’s take a closer look at the recent updates and what they mean for SCIP compliance.
SCIP Updates: SCIP Format V2
The current format of SCIP is the offspring of collaboration between stakeholders and a group of dedicated IT users. ECHA’s objective is to offer a reporting system that will respond to the need for more responsible sourcing, manufacturing, and recycling, all the while minimizing reporting work and redundancies for companies as much as possible. The latest updates are designed to include simplifying mechanisms and facilitate automated SCIP submissions.
Overview of Significant Format Changes
Origin of Product
The previous version proposed a basic “yes,” “no,” or “unwilling to disclose” to the EU production picklist. Options today are “no data,” “EU produced,” or “both EU produced and imported”
Candidate List
The newest update no longer offers to select which version of the candidate list is relevant to the submission. It now assumes businesses are working with the most up-to-date list.
Data Already Submitted to ECHA
This is arguably one of the most productive changes to the SCIP format. ECHA article ID now becomes the SCIP number, allowing data previously submitted to ECHA to cross over and avoid re-submitting for the same article, even though it’s sourced from a different supplier.
Number of Units
SCIP updates moved from a limiting report on the number of units to a range of units. Using a more than/less than entry allows for better reporting on production variances.
Format Compatibility
ECHA has created an IUCLID format for files ready for submission. The newest version contains the SCIP updates on format changes and permits both forward and backward compatibility, a quite useful feature for organizations that have already started dossier preparation.
Getting Started and Getting Ready
January 2021 is a fairly packed month when it comes to compliance reports and submissions, including but not limited to Brexit deadlines and EU Conflict Minerals. Regardless of unforeseen regulations to come in 2021 such as the potential Uyghur Forced Labor Prevention Act, most compliance programs consider it business as usual.
This article merely highlights some of the most significant SCIP updates in terms of formatting submissions. If you’ve been experimenting with the SCIP database this year, chances are you’re confused, overwhelmed, frustrated, or all of the above. That is only natural with new reporting programs aiming to report digestible data.
Ever since the inception of the program, Source Intelligence has closely followed changes and updates and adapted its solution accordingly.
What you should start to do now:
- Identify articles that contain any listed substance (0.1% weight to weight)
- Assess gaps in your data (engage your suppliers) and identify high-risk articles.
- Gather the necessary information from your suppliers
- Understand how to roll up data into SCIP dossiers
If you’ve been following the SCIP saga, you’re likely to know it sounds easier than it is. Source Intelligence specifically designed a SCIP solution to build a bridge between you and your suppliers.
By closing the data gaps in your supply chain, we provide you with the means to collect, aggregate, and utilize data, then submit with confidence. Our job is to do the heavy lifting and let you enjoy the peace of mind that comes with being compliant.
Request a demo of our SCIP database compliance solution today to see what it can do for you.
