COMPLIANCE RESOURCES
SCIP Database
Frequently Asked Questions
As of January 2021, companies placing articles on the EU market which contain reportable levels of Substances of Very High Concern (SVHCs) under EU REACH will need to submit their product information into the Substances of Concern in Products (SCIP) Database as part of the requirements under the EU Waste Framework Directive (EU WFD).
The below FAQs will guide you through the most common issues companies encounter when dealing with the SCIP Database.
SCIP Requirements
Who needs to comply with SCIP?
Companies with products containing SVHCs over 0.1% w/w at the article level ("reportable SVHCs") have an obligation to notify their down-stream customers.
EU producers/assemblers, EU importers, and EU distributors of articles and other parts in the supply chain who are placing articles on the EU market all need to comply with the SCIP Database submission requirements.
Even companies that are not directly required to comply will often be requested by their customers to provide the necessary data so that the customers can submit their product information to the SCIP Database.
If I produce purely for export, do I still have to submit to the SCIP Database?
No. Only articles which are placed on the EU market are subject to SCIP notification obligations. Articles produced within the EU purely for export outside of the EU are not in scope.
What information is required for SCIP Database submissions?
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 EU 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
- Determine the concentration range of the reportable SVHC within the reported article
- Determine if the article was produced or assembled within the EU
Updating SCIP Submissions
What is the process for updating a SCIP submission considering that the EU adds Substances of Very High Concern (SVHCs) twice per year and may add one that is in our articles?
If a new SVHC is added to the SVHC Candidate List, and the new substance is present in an article within a product you have previously notified to the SCIP database, then simply update your dossier accordingly and resubmit. The SCIP notification will be updated, and the SCIP Reference ID for the product will remain the same.
SCIP Reference IDs
Do spare parts that are also sold and shipped separately need separate SCIP Reference IDs than the appliances that they are spare parts for?
Yes, if parts are placed on the market for sale, these must be considered separate products being placed on the EU market.
Administrative
When is the SCIP implementation/enforcement date?
As of January 5, 2021, any articles or complex objects placed on the market within the EU must have a corresponding submission into the ECHA SCIP database if the item contains within it any articles with SVHCs over 0/1% w/w.
Read More
Submit your email below to immediately access the full set of 30+ frequently asked questions.
