Considering SCIP – Substances of Concern In articles as such or complex objects (Products) as the latest and evolving regulatory trend for all industries, our compliance team at APA Engineering is closely monitoring all changes to avoid any problems in meeting our customer requirements. To be at the forefront of this race, we are an active member of the ECHA SCIP IT User group providing suggestions on improvising SCIP IT tools and process reporting.

ECHA is considering some upgrades for SCIP reporting which was shared in the last held SCIP IT user group meeting on 25th March 2021. Quoting down some major updates which can be expected in the upcoming months.

a. Dissemination of ECHA SCIP Database

The main objective of the SCIP database is to make SVHC information in products available to waste operators, consumers & government authorities and in turn contribute towards the EU Circular Economy concept. On March 18th, ECHA announced that due to some technical issues, there will be a delay in the dissemination of SCIP information and the new date of release will be announced soon. Based on stakeholder’s opinion, ECHA is also considering to build a feature which will allow searching for information using SCIP number.

b. Handling of SCIP Dossiers with more than 1000 Components

ECHA has communicated that they cannot process SCIP dossiers consisting of more than 1000 components. So, from the end of April’21, an upgrade in the ECHA submission portal will notify the users regarding this concern and the SCIP notifications will get rejected stating this technical issue. And dossiers received within the period 26th March-30th April won’t be processed further and will be under pending status. Finally, these also will get rejected after April and stakeholders need to make resubmissions by improvising the data structure.

For the submissions received before March 26th, ECHA will reach out to the submitters for understanding their concerns and supporting them in making simpler SCIP notifications. To avoid all such hurdles in the future, ECHA is strongly recommending going through the documents published on the ECHA website and make use of the features offered to create simplified notifications.

c. Optimization of SSN (Simplified SCIP Notification) Feature

SSN enables duty holders to make SCIP notifications directly in the ECHA portal by referring to SCIP numbers. Under this approach, preparation of the IUCLID dossier is not required, which is the most time-consuming activity in the SCIP reporting process. Mainly this feature was introduced for distributors who don’t make any changes to the product. But later the scope got expanded to corporate groups with multiple divisions. ECHA noticed many failures while using this feature in the last few months. So, it has been suggested to avoid any duplicates in SCIP numbers before exporting the SSN list to the portal.

In addition, ECHA is also thinking of enabling SSN submissions for multiple legal entities (Multi-LE SSN submissions). Using this, a user with “Foreign User” access will be able to submit SSN for different legal entities in one step. Currently, it is possible only to make SSN to one legal entity at a time.

APA Engineering is offering a system-system software solution, which can be used for all industries to meet their SCIP requirements without any barriers. If you are looking out for SCIP Services reach us at [email protected]