Manufacturers must be prepared to register designated products in SCIP starting in January 2021. There are services available to help to implement this process – the time is NOW to prepare!

What is SCIP database?

Substances of Concern In articles as such or in complex objects (Products), in short as SCIP is the newest approach for the EU to better manage the use of potentially dangerous chemicals or materials. The intent of SCIP is to bring awareness on the use of these items and how they impact the environment and overall health in the EU. SCIP focuses on the waste disposal of the substances of concern.

Read the SCIP Compliance FAQ to make submission process simple.

ECHA (European Chemicals Agency) oversees SCIP as well as REACH compliance and the IUCLID software that supports the database.

Why is SCIP important?

By elevating the usage and disposal information about SCIP items, waste operators and consumers can take steps to reduce the health and environmental impacts. Also, manufacturers can better examine alternatives to these potentially hazardous substances.

Who is required to participate in EU SCIP database?

If your company is selling products that contain substances of very high concern (SVHC’s), you should do an evaluation on your SCIP requirements. Products sold in the EU market containing SVHC’s in concentrations above the threshold limit (0.1% W/W) are responsible for submitting documentation to the ECHA SCIP database that includes mainly Manufacturers, Assemblers, Importers & Distributors.

The only exception to EU SCIP database participation at this time are retailers who are directly supplying products to the consumers without making any alterations.

In case of non-EU companies that would otherwise be out of scope for SCIP, they are obliged to provide the required information and support their importers in making SCIP submissions. In addition, if the company has a European Chemicals Agency (ECHA) account under a “Foreign user”, they may make direct submissions to the database.

Which are the major milestones of the EU SCIP Database?

On 4th July, 2018, Revised Waste Framework Directive entered into force and entitled ECHA with the task of developing a database with information of products containing SVHC’s.

Following this, ECHA developed SCIP and released its prototype on 17th Feb 2020 for its stakeholders to equip themselves for the SCIP requirements. The final version is planned to be released by October 2020 where they can start making the final submissions.

The SCIP obligations for legal entities kicks in by 5th Jan, 2021, so get ready to report before that.

How SCIP requirements differ from REACH?

REACH is the regulation on Restriction, Evaluation, and Authorisation of Chemicals. The main differences lay in the declaration requirements. In case of the ECHA SCIP database, the requirements are much more complex compared to ECHA REACH.

As per Article 33 of REACH regulation, all suppliers of articles containing any SVHCs above 0.1% (w/w) should communicate the substance name and available safe use instructions throughout their supply chain. And a single declaration can be done on product level basis.

With the EU SCIP, more information is required at the substance & article level in order to make a successful submission. It includes Article identifiers, article categories based on TARIC codes, article characteristics, material/mixture category, substance identifiers & its concentration ranges, safe use instructions and many more. Moreover, the SCIP submission should be made at the article level, which means separate article dossiers need to be prepared with the included SVHCs linked under the complex object.

APA Engineering has written a detailed comparison of SCIP database and REACH regulation to clear the myth.

What information is required from suppliers?

The information requirements from supplier can be categorized into 3 elements:

a)  Article Identification which includes article name, identifiers (EAN/GTIN/GPC/ECHA article ID/catalogue number/part number), article category based on EU TARIC codes, part produced in EU (Yes/No) & other characteristics (picture, dimensions, weight, color).

b)  Concern Element which includes applicable candidate list version, SVHC name, concentration range, material/mixture category.

c)  Safe use instructions or Disassembling instructions

d)  Name & quantity of the linked articles (containing SVHC) in the case of complex objects

What software or tools do I need to access to make a SCIP submission?

For making a SCIP submission, each company needs a valid ECHA account and a subscription to the IUCLID Cloud service & ECHA submission portal. Once it is available, there are three ways data can be prepared and submitted:

a)  Online preparation in IUCLID Cloud where ECHA provides a user interface to prepare & submit SCIP data.

b)  Data preparation ‘offline’ in the company’s own IT infrastructure by downloading IUCLID 6 Cloud and then data is to be prepared in harmonized SCIP format, which can be downloaded from ECHA website. Otherwise, data submission will not be successful.

c)  Automation of SCIP submissions using system to system service. Through this, companies can make the submission process automated with a software preparing dossiers in SCIP format and then getting access for S2S service from ECHA

How does SCIP get used?

There are three primary users for the SCIP information:

Consumers – The SCIP information will be publicly available, so those who have a concern about a particular product or substance can quickly check the database.

Waste operators – these companies come in direct contact with SCIP substances, and having clear knowledge of the items and the recommended disposal process is an essential step to safely reduce risk of exposure or environmental harm.

Suppliers and Manufacturers –companies that create, assemble, or distribute products that have SCIP substances must register. The information in the registration process can help suppliers to look at options and alternatives to reduce overall use of the substances.

How can I check to see if my product requires SCIP registration?

Several steps must be taken to determine if the substances within a product should be registered:

1. Get a bill of material (BOM) on the product, or examine the ingredients listing of the product.

2. Get the latest SVHC candidate list downloaded from ECHA website

3. Compare the substances used in the manufacture of the product to the SVHC Candidate List using the ES / CAS, CAS number, or name.

4. If the usage of a substance included in SVHC Candidate list exceeds a concentration of 0.1% weight by weight, SCIP registration is required.

What are the SCIP registration steps for a manufacturer or supplier?

Because of the rapidly increasing knowledge on the handling and disposal of potentially dangerous substances, ECHA is updating the SCIP registration steps. Careful monitoring of the changes should be part of an ongoing process to stay updated and to comply with the registration requirements.

These are the current process steps:

1. Perform the check on any SCIP items with the Candidate List as described above.

2. Whenever the manufacturing process changes, take steps to audit and update based around SCIP requirements.

3. Complete the specified form required to submit SCIP information.

4. Note there are over 20 different validation checks that occur as part of the SCIP registration process, so the information submitted will be checked thoroughly.

5. Submit the SCIP information and await confirmation and validation.

6. Review and update the SCIP information on a regular schedule or when a change is made in the manufacturing process.

What data is needed on the registration forms?

There are many field requirements, but the following are some of the more important:

– Article information, including name, GTIN/EAN/etc and whether the article has production in the EU.

– Concern element, with candidate list reference information and concentration range.

– SCIP registration effective date and legal entity information of the submitting company.

– File must be generated in XML, csv or excel format.

Where to start?

Begin by going through the guide available on the ECHA website and also get access to the IUCLID database.

You can also partner with a company who already understands the EU SCIP database process and stays up to date on the evolving requirements. APA Engineering helps navigate through SCIP by providing software to manage the supply chain data and a team of SCIP experts to ensure accurate submissions to ECHA.

About APA Engineering:

Established in 2000, APA specializes in providing turnkey compliance services for manufacturers across REACH, RoHS, IMDS, SCIP, SDS, Prop65.

APA combines domain expertise, software tools and clear processes to achieve high standards of compliance that leading manufacturers expect.

Using APA Engineering will save you time and extra resources, while giving you the confidence to achieve compliance and be ready to conduct business safely in the EU and anywhere else in the world.

Contact APA Engineering to get information and a demo of the SCIP software features!