The Substances of Concern in Products (SCIP) database was established under the European Union (EU) Waste Framework Directive (WFD) after the WFD was revised in 2015. The Substances of Very High Concern (SVHCs) that must be reported on and submitted to the SCIP Database are established under the EU Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) regulation. In general, companies within the scope of REACH must also comply with WFD and SCIP database reporting requirements.
As of January 5th, 2021, EU manufacturers, assemblers, distributors, and importers must follow the SCIP database reporting requirements set by the European Chemical Agency (ECHA). It’s important for companies to understand the differences between SCIP and REACH reporting to ensure ongoing compliance with both entities. We explain the differences between the SCIP database and REACH regulation reporting requirements below.
The two main differences between the SCIP Database and the EU REACH regulation are their intended purpose and the data required for reporting. While SCIP and REACH both require companies to report on the presence of SVHCs in their products, the reporting requirements, and how the collected data is utilized, differ between the two. SCIP reporting is more extensive, requiring information beyond what is required for REACH reporting.
The purpose of the REACH regulation is to improve the protection of people and the environment from the risks posed by harmful chemicals restricted under the regulation. It aims to reduce the use of hazardous chemicals in the product design phase.
SCIP takes the goal of REACH a step further—the intent of the SCIP database is to reduce the negative impacts of waste materials on people and the environment by informing waste operators and consumers about how to properly recycle and dispose of products containing SVHCs.
In addition to their individual goals, SCIP and REACH have a shared goal of encouraging companies placing products on the EU market to utilize safer alternatives in their products.
As mentioned earlier, both the SCIP Database and the EU REACH regulation require companies to report on their use of SVHCs, but more information is required to comply with SCIP reporting requirements.
Let’s break down the differences between the two:
Per REACH Article 33, EU manufacturers, producers, assemblers, importers, etc., must declare the presence of SVHCs at a concentration above 0.1% weight by weight (w/w) at the article level. To comply with EU REACH reporting requirements, companies are required (at a minimum) to provide the names of any SVHCs present along with any safe use information.
Beyond those minimum requirements, there is no formal declaration template for REACH. Companies can submit declarations, safety data sheets, certificates, test reports, etc., as valid data for REACH compliance. The data collected from REACH reporting is meant to be used by other actors in the supply chain using the parts in their product, or by consumers purchasing the final product.
The REACH SVHC list is updated twice a year, which means companies must collect current data throughout the year to remain compliant. Complying with the REACH reporting requirements can be challenging and resource-intensive but utilizing a supply chain compliance solution—such as our REACH program—can help simplify the process.
The same types of companies within the scope of REACH are also within the scope of SCIP. Moreover, like REACH, SCIP requires companies to submit information to the SCIP database for any products that contain SVHCs above a 0.1% weight by weight (w/w) threshold. The SVHCs covered under SCIP are based on the REACH SVHC candidate list, and substances must also be reported at the article level.
However, unlike REACH, SCIP has a standardized reporting process with a specific template: a SCIP dossier. Companies must submit SCIP dossiers to ECHA to remain compliant with the SCIP database reporting requirements.
In addition to the name of the SVHC and its safe use information—the only information required for REACH reporting—SCIP also requires data on the exact articles which contain the SVHCs, information about where they are in the product, and the material which contains the SVHC. Examples of required data include material identification, article category, and article numbers.
Dossiers can be submitted manually with the ECHA Submission Portal or automatically through a system-to-system (S2S) transfer. Once a dossier is submitted, it is assigned a SCIP number and publicly listed in the SCIP database for waste operators and consumers to access at any time.
Partnering with Source Intelligence helps reduce uncertainty around SCIP compliance by streamlining the data collection and reporting process. Our SCIP program collects data from suppliers (the most recent REACH SVHC and SCIP article data, along with supporting documentation), and our team of regulatory experts reviews the data for completeness and quality. With the approved data, our program generates SCIP reports, enabling you to perform gap analyses and submit SCIP dossiers.
Whether you need your SCIP compliance processes managed by our team, or you need dynamic software that helps support your compliance goals, we’ll find the best fit for you.