SCIP Compliance Notifications

The European Chemicals Agency (ECHA) has put forth Jan 5th, 2021 as the official date to begin receiving SCIP submissions from distributors. As a business, if you are wondering why this is important, let’s break it down in simple words.

The ECHA SCIP database is intended to contain all information on Substances of Concern In articles as such or in complex objects (Products) established by ECHA under the Waste Framework Directive (WFD), Article 9(2).

The SCIP database’s purpose is to reduce the amount of hazardous waste by supporting the use of replacement substances in articles entering the EU. By doing so, the EU aims to monitor and reduce the overall use of hazardous chemicals.

Companies doing business in the EU — whether producers, assemblers, importers, distributors or any other type of business placing articles containing SVHCs above the threshold on the European market — must submit notifications to the ECHA via the database.

However, navigating through the ECHA SCIP database requirements is not a simple task for everyone. To ease the process, we will take you through a few approaches which will simplify SCIP notifications for you with minimal errors.

Read more on the most asked questions on challenges faced during ECHA SCIP database submission.

Simpler Approaches Towards SCIP Notification

Approach 1 – Simplified SCIP Notification (SSN)

Distributors are the main target users for SSN. The actual working of SSN is quite simple. In this approach, the distributor submits a notification by referring to data submitted by his supplier. This is done via an alphanumeric identifier that the supplier receives after notification from the distributor.

SSN follows 3 basic principles

1. The product received is the same as the product supplied

2. The submission does not require any dossier

3. The distributor links to the notification of the supplier and does not need to submit updates

A large number of distributors rely on SSN to simplify their submissions. Another similar approach to SSN is referencing. Both ultimately differ in terms of target users

Approach 2 – Referencing

Referencing refers to articles that are already notified when incorporated into complex objects. This process is more advantageous for the assemblers.

Highlights of the Approach:

● It only applies when the article does not change

● The assembler links himself to a chain of submissions for a specific article

● Additional components or information cannot be added to a referenced article

Approach 3 – Submission on behalf of the foreign user

This is a simple approach which allows third parties to submit data on your behalf based on the arrangements between the distributor and supplier in prior.

Who is it useful for?

● Corporate groups, where the parent company wishes to submit data on behalf of its daughter companies

● Voluntary arrangements between companies (e.g. a brand owner submitting on behalf of a full and closely controlled supply chain)

● Consultants or other third parties supporting duty holders

Individuals often get confused between the REACH and ECHA SCIP compliance. Learn more about the differences between REACH and ECHA SCIP Database here.

APA engineering has provided a list of highly useful tips to help you achieve REACH compliance. If followed, these tips will help you unburden the difficulties of the process and complete it seamlessly.

Approach 4 – Grouping

Many times, there are cases that require just a single submission to complete the ECHA SCIP database submission process. Let’s go through a few of the cases:

● Case 1 – When the articles are identical in nature, a single submission suffices. The identical nature of articles could be due to identical physical forms, identical chemical composition, or almost similar functions.

Example: A very valid example would be 50 identical O rings which are similar in every aspect.

● Case 2 – When the articles are quasi identical, they can have the same function, but the articles can differ in terms of material composition and the overall physical forms. Even this case requires a single submission.

Example: – A group of O rings build from the same material but differ in terms of color/diameter/ width.

● Case 3 – This case is often referred to as Representative article approach or worst case reporting. As a business, you can report all the worst combinations of articles with SVHC under a generic identification.

Example: Printed circuit boards with 2 resistors from different suppliers, and different SVHC’s as well.

Since the SCIP database is maintained by the European Chemicals Agency (ECHA), there are pre-approved methods to prepare a notification. The three approved ways are

● Online, using the ECHA IUCLID cloud services and Submission Portal

● Offline, using the IUCLID software installed on internal personal computers (PCs) and servers

● Through system-to-system (S2S) transfers where data is managed in IUCLID-acceptable formats

The fourth and most easy suggested method would be to partner with a third party vendor like APA Engineering, who can take care of all regulation management for your business and essentially assist you in saving a significant chunk of your time and resources.

If you have more concerns on ECHA SCIP, we have curated proven tips to help you in simplifying ECHA SCIP database submissions.

Wrapping Up

The most reliable way to identify those hazardous substances is through laboratory testing. As an individual or an organisation, you can carry out testing by yourselves or ask your suppliers to do it.

For consumers, the SCIP Database provides a ‘right to know’ about substances of very high concern in the products they purchase. By doing so, ECHA assures a high level of transparency to multiple stakeholders, including Consumers, Businesses, and Regulatory Bodies worldwide.

Due to dedicating time to a high number of compliance requirements, you might miss out on other key aspects of your business. That’s why it is always suggested to get services from a reliable and experienced regulation management provider like APA Engineering. With years of expertise in offering compliance management solutions to numerous brands across industries, APA Engineering comes with proven experience in REACH, SCIP, IMDS, Conflict Materials or all other regulatory compliances. Get in touch with our success managers today, and learn all you need to know about the consultancy and management services we provide in your domain.