During the last week of October 2020, the SCIP database will be formally open for submitting notifications to legally comply with the SCIP compliance, which is two months in advance of the entry into application date. As outlined in the waste framework directive, the obligation to officially submit data to SCIP starts to apply from 5 January 2021.

ECHA has no indications that the deadline would be postponed and encourages companies to continue their preparations.

Trade body SMEUnited recently expressed its concerns over the SCIP compliance. One of their main concerns arises due to the complexity of the reporting, which is extraordinarily high as per the trade body.

Specifically, SMEUnited is concerned because companies are required to notify Echa via the database of composition changes to their articles. And this will put financial and resource strains on SMEs. Every supplier within the same supply chain needs to renotify an already previously notified article,” it said, adding that for such cases, there is a need to develop criteria that allow grouping of similar components/articles into one notification.

ECHA has already released a statement that they are developing solutions to simplify the notification system. In light of the various challenges associated with SCIP compliance, we are going to discuss some of the most critical ones to increase awareness and assist in your compliance requirements.

Critical Challenges Associated With ECHA SCIP Compliance

1. Manual Submission

If the vendors or distributors decide to go with manually completing the ECHA SCIP submission, the decision can lead to several challenges. The challenges range from part identification to data collection from the supply chain and creating the data in IUCLID as per ECHA SCIP format. It is advised not to miss out on any key aspect while completing the submission as it can lead to regulatory fines and business issues.

One recommended way to avoid this is by understanding the differences between various compliances. Click here to know the exact differences between REACH and SCIP database.

2. Identifying SVHC substances in IMDS data

As a part of the submission process, you are required to identify each and every article in your supply chain that uses SVHC(Substances of Very High Concern) in production. This step can be problematic, especially for companies with low resource availability as can be a very time-consuming task.

Additionally, you are required to contact your supplier to get a detailed and complete material declaration for the substance break-down data. REACH compliance certificates are not sufficient enough to make the SCIP submission. An authenticated material declaration from the supplier is a crucial step when filing for the SCIP submission.

3. Realistic Legal Challenge

In a letter to European Commission DGs Environment and Grow, trade body SMEUnited says ECHA could be asking for information beyond legal requirements. This is a part of the submission process that the other stakeholders too, have raised as a concern during the development of the database. And due to these “ongoing legal and practical discussions,” it expects “continuous adaptations”.

The letter also pointed out that SMEs do not have the resources to regularly implement adaptations which will make the updates highly problematic for them. To avoid all such troubles, it is highly advised to get expert assistance from an experienced third party compliance solutions provider. We have compiled the best approaches to simplify the ECHA SCIP notifications to assist you.

4. Identifying The Correct Product Hierarchy

Not all articles used in manufacturing contain SVHC in singular quantities. Due to the complex nature of formulation and production, articles used to consist of numerous SVHCs in multiple nodes at level 10 or higher. As such, it becomes quite tricky to rightly identify the product hierarchy for every article and therefore poses a challenge in complying with the ECHA SCIP regulation.

APA Engineering has released a list of the most common FAQs related to SCIP database submission challenges.

5. Multiple Stakeholders

Large organizations having multiple decision-makers and stakeholders to execute one process often creates chaos. They devote a colossal amount of resources trying to fight the last moment troubles with regulatory management. Communication delays, inconsistent follow-ups and information lag can disrupt the activity and badly affect the expected outcomes.

As such, delegating the entire compliance work to one single unit or a third party vendor can vastly help in avoiding the chaos. It’s a smart idea to get help from an experienced regulatory solutions provider who can do all of that work for you without the need for micromanagement.

There’s also an imminent need to simplify the overall submission process. Click here to understand in detail the various requirements to streamline the ECHA SCIP database submissions.

Industry experts say it is highly disproportionate that a “person or small company, who earns a very modest income, has the same obligations as a multinational”. ECHA, on the other hand, very rigidly states that the legal obligations do “not apply to suppliers who sell directly to consumers, which excludes retailers and many other small businesses from the scope.

Wrapping Up

Apart from the businesses that are exempted by ECHA, all others should strictly adhere to the regulations to avoid any kind of regulatory overwatch and monetary fines. You can easily avoid such troubles by getting in touch with APA Engineering, who are pioneers in providing managed regulatory solutions.

APA Engineering has 20+ years of rich experience in providing valuable insights, support, and regulatory management services to its broad base of trusted clients.

With our vast expertise in ECHA SCIP, IMDS, REACH, Conflict Minerals, and other compliances, we make sure you and your business have one less issue to worry about. Get in touch with experts from APA Engineering today and find out how you can achieve 100% compliance fulfillment.



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.