One month after the launch, ECHA have received 52, 676 notifications to the SCIP database.

Tips from ECHA to improve submissions

For the 7 % of submissions that have failed, the main reasons for that outcome are related to a failure of the validation rules which prevent the submission of the same notification twice by the same company and submissions by non-EU companies.

In addition, some companies plan to submit dossiers of disproportionate size. ECHA strongly recommends including a maximum of 1 000 components within one dossier. Bigger dossiers will be very complex to understand for waste operators and consumers.

Make sure you only report components containing Candidate List substances.

● Include a clear and understandable identification of your articles to make the information useful for the database’s users.

● Avoid redundant layers of components and sub-components. A very complex hierarchy does not necessarily bring any benefit in identifying the article containing the Candidate List substance. For most common products, two to five layers may be sufficient, while for the most complex ones the number of layers should be as low as possible, potentially no more than seven.

● To avoid duplication, use the option to refer to data already submitted by others.

● To the extent possible, group similar articles following ECHA’s recommendation.

● If necessary, split up big dossiers by notifying the larger components separately (e.g. engine, seats, battery) and then reference them in the top-level complex object (e.g. car) notification. This will also facilitate future updates and reduce the need of preparing new notifications.

● Contact us for advice before submission, if these measures don’t help to reduce the complexity of your notification.

Submit only complete and clear dossiers: successfully submitting an incomplete dossier does not make you compliant. Instead, it increases your workload as you will need to resubmit.


If this regulation is applicable to you and you are interested in knowing more about this topic and available solutions, then schedule a free consult with our experts.