Effective January 5, 2021, suppliers of articles were required to submit information regarding Substances of Very High Concern (SVHC) for human health and environment in articles or complex products to ECHA's SCIP public database, which was established under the Waste Framework Directive. The SVHCs are listed in the Candidate list, updated bi-yearly by ECHA (European Chemical Agency). The SCIP database contains more than 7 million articles that have helped improve the transparency of hazardous substances through the entire product life cycle.

The objectives of SCIP:

• Find alternatives for substances of very high concern to reduce waste generation.
• Enhance the Circular economy by designing products for reuse, remanufacturing, and recycling.
• Enabling information transparency by making data available throughout the life cycle of the product to waste operators who can make informed decisions about safe handling, treatment, and disposal of wastes; to consumers who can make informed decisions about sustainable products; to authorities who can monitor the substances of concerns in the articles/products in the EU market.

Meeting SCIP obligations as manufacturers:

Any manufacturer, distributor, importer, or assembler and those involved in the supply chain supplying articles/complex objects/substances containing SVHCs based on the ECHA Candidate List in the concentration above 0.1% w/w in the EU market must notify the SCIP database in SCIP format1 (XML format compatible with IUCLID).

A manufacturer’s final SCIP Reporting success lies essentially in the SCIP data being available from their upstream suppliers. Let’s see how to effectively comply with the challenging task of notifying
the SCIP database by following these 7 strategies:

1. Set up a clear process: Manufacturers should develop a well-defined process within their organization to handle SCIP compliance. This includes identifying responsible individuals or teams, establishing timelines, and defining the necessary steps from data collection to submission.
2. Conduct thorough product assessments: Manufacturers need to conduct comprehensive assessments of their products first to find out if they are obligated to meet SCIP reporting, and if so, identify substances of very high concern (SVHCs) that meet the SCIP notification threshold. This involves gathering information from suppliers, conducting material evaluations, and utilizing available resources like the Candidate List of SVHCs published by ECHA.
3. Collaborate with the suppliers: Once a thorough assessment of the product has been conducted map the components with their suppliers, identify missing supplier data (both EU and non-EU suppliers), and compile the missing data to be sent to the respective suppliers requesting for detailed documentation.
4. Implement data management systems: Adopting robust data management systems, such as specialized software or databases, can streamline SCIP compliance. These systems help organize and centralize information on product compositions, SVHC presence, and other relevant data required for SCIP notifications, monitor and track information from suppliers and automate the SCIP process end-to-end until reporting.
5. Generate/Compile the SCIP Dossier: Once you have the required SCIP information available, draft the notification in SCIP format1.
6. Submit the SCIP Dossier: Submission of the SCIP can be done offline through the IUCLID Desktop Application, online via IUCID or System to System submission (by connecting third-party systems like Greencheck to the EU SCIP database)
7. Stay updated on regulatory changes: Get the latest regulatory updates and guidance provided by ECHA regarding SCIP notifications. Manufacturers should regularly check for new substances added to the SVHC Candidate List, changes in SCIP reporting requirements, and any other relevant updates that may impact compliance.

Next, what if Manufacturers don’t meet the SCIP obligations?

1. Legal repercussions: Failure to comply with SCIP notification obligations can result in legal consequences. Regulatory authorities may initiate enforcement actions, impose penalties, or apply other legal measures according to national legislation. This can include fines, sanctions, or limitations on the ability to market products within the European Economic Area (EEA).
2. Business reputation and market access: Non-compliance with SCIP notification requirements can harm a manufacturer's reputation. Customers, suppliers, and stakeholders may view non-compliance negatively, potentially leading to a loss of trust and business relationships. In addition, non-compliance may restrict market access within the EEA, as compliance with regulatory obligations is often a requirement for product placement.
3. Disruption in the supply chain: SCIP compliance is a shared responsibility within the supply chain. If manufacturers do not fulfil their SCIP notification obligations, downstream users may face challenges in meeting their own compliance requirements. This can disrupt the flow of information and potentially impact business relationships.
4. Increased scrutiny and audits: Non-compliance with SCIP notification requirements may result in increased regulatory scrutiny. Authorities may conduct audits or inspections to assess compliance levels. This can lead to additional administrative burdens, reputational risks, and potential fines or penalties if non-compliance is identified.
5. Limited access to information: SCIP aims to improve the availability of information on hazardous substances in articles. If manufacturers fail to submit SCIP notifications, it hinders the overall goal of transparency and may limit the availability of information to downstream users, consumers, and waste operators. This can undermine efforts to ensure the safe handling, treatment, and disposal of articles containing hazardous substances.

Stay compliant with SCIP, we are here to help!

APAs automated tool “Greencheck” can help you comply with SCIP notification. Data collection, integration, dossier preparation and submission has never been this easy! Talk with our experts today!

For more interesting reads!

• Handling SCIP challenges
• Solution for ECHA SCIP Database