Data Services and Software Solution for SCIP Database Submissions
GreenSoft’s SCIP Database Solution
GreenSoft has a solution for EU REACH Substances of Very High Concern (SVHC) and the SCIP Database as required under the EU Waste Framework Directive.
As part of our Data Services, we will collect data on reportable SVHCs from your suppliers, including article and material classifications, and all other information needed for mandatory SCIP data requirements. And we validate that data for accuracy and completeness.
We also help assess and assign article and material category classifications to the reportable SVHCs in your products when suppliers are unable to supply such classifications as required when submitting to the SCIP Database.
Using our GreenData Manager with SCIP Module (GDM w/ SCIP) software, we can automatically generate SCIP dossiers for upload to the SCIP Database.
Developed by engineers and regulatory experts, GreenSoft’s comprehensive Data Services and GDM w/ SCIP software provide the unique ability to validate the contextual content needed for SCIP Database submissions.
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Who Needs to Comply?
EU producers/assemblers, EU importers, and EU distributors of articles and other parts in the supply chain placing articles on the EU market all need to comply with the SCIP Database submission requirements. But even companies that are not directly required to comply will often be requested by their customers to provide the necessary data for them to submit product information to the SCIP Database.
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Your Obligations for SVHC and SCIP Database
Both the EU REACH regulation and the EU Waste Framework Directive require companies to evaluate and communicate or report on the risk of hazardous substances within their products. In order to do this, companies must collect and assess the chemical data of their products and components from their supply chain.
EU REACH Substances of Very High Concern (SVHC)
Companies with products containing SVHCs over 0.1% w/w at the article level (defined as “reportable SVHCs”) have an obligation to notify their down-stream customers.
The list of SVHCs grows and changes every 6 months, so Compliance Statements for components claiming EU REACH compliance have very short lifespans.
The best method for companies to manage the substance data on their products is to collect Full Material Declaration (FMD) data from suppliers so that substances can be re-evaluated every time the SVHC list is updated without having to recollect data from suppliers.
EU Waste Framework Directive (WFD) SCIP Database
As of January 2021, companies placing articles on the EU market which contain reportable levels of SVHCs under EU REACH will also need to submit their product information into the Substances of Concern in Products (SCIP) Database as part of the requirements per the EU WFD.
Submissions to the SCIP Database require significantly more information than EU REACH SVHC communication obligations.
Suppliers of articles with SVHCs over 0.1% w/w need to submit the following information to the SCIP Database:
- Name of the substance and its safe use (originally/currently required under Article 33 of REACH)
- Determine the category of the article containing the reportable SVHC (selected from a list of over 20,000 options)
- Determine the category of the material or substance (mixture) which contains the reportable SVHC
- Linking of articles that contain the reportable SVHC within complex objects including number of occurrences
- Determine the concentration range of the reportable SVHC within the reported article
- Determine if the article was produced or assembled within the EU
Data Collection, Validation, & Supplier Guidance
As part of our Data Services, GreenSoft will collect SVHC compliance data from your suppliers. Since the SCIP Database is still new to suppliers, the amount of suppliers who will be capable of providing this complex data (such as article category and material category from a pick list of 20,000 options) without errors is small. We provide guidance and education to suppliers to help improve response rates and data accuracy.
GreenSoft’s data collection team will actively pursue unresponsive suppliers via telephone and email as many times as it takes to obtain the required data. We then validate that data to ensure it is complete and accurate. This person-to-person data collection model allows for validation not only of the presence of the data, but of the contextual content of the data as well.
Submissions to the SCIP Database require data to be classified into article categories and material categories from a list of over 20,000 options.
GreenSoft will work with the suppliers to determine the category of articles and category of materials in your products which contain reportable SVHCs, and if suppliers fail to provide category classifications, we will perform classification assessments on article categories and material categories to fulfill the data requirements for SCIP database.
GreenData Manager Software
Our GreenData Manager with SCIP Module (GMD w/ SCIP) software is a powerful tool that allows for complex data processing and article analysis. Companies can use GDM w/ SCIP software to manage their EU REACH compliance and SCIP Database reporting themselves, or GreenSoft’s team will generate reports and SCIP dossiers from GDM w/ SCIP for you as part of our Turnkey Services.
GDM w/ SCIP software features include the identification of reportable SVHCs in Bills of Materials (BOM), components, articles, and materials/mixtures. GDM w/ SCIP can assist in completing data requirements to prepare SCIP dossiers and export the dossiers into IUCLID i6z format for submissions. You can choose to submit SCIP dossiers one at a time or process them in bulk through a system-to-system transfer to the SCIP database.
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