The advent of SCIP database brings along numerous questions in mind to its stakeholders. As from 5 January 2021, information on articles containing SVHCs (on the Candidate List) in a concentration above 0.1 % w/w placed on the EU market needs to be notified to ECHA. Although the SCIP submission process is not too difficult to execute, you could face a few challenges along the way.

To assist you in the process of SCIP submission, we have come up with a list of top FAQ’s that will help you in making the submission process more streamlined, and free of any flaws for safeguarding your business.

But what if your question is not listed here?

In that case, you can contact APA Engineering, which specialises in offering end to end SCIP management solutions. With an immaculate grasp of handling all the compliance challenges, APA Engineering provides holistic support to businesses in their SCIP submission process.

SCIP Submission Process Related FAQ’s

1. How can I identify SVHC substances in IMDS data before the submission process to ensure precise reporting?

You can easily identify SVHC substances through the underlined substances in IMDS. This is a feasible way to identify a few items. Still, in case of larger volumes of individual parts, you are going to need external help of an expert to correctly identify the adequate usable quantities and legality of the articles.

2. When considering equipment like non-automobile parts, where can I get the substance break-down data of the same?

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. What challenges will I face if I decide to proceed with manual SCIP submission?

Multiple challenges are expected if you decide to go with manual SCIP submission. The challenges range from part identification to data collection from the supply chain and creating the data in IUCLID as per ECHA SCIP format. To learn more about the IUCLID filing process, click here.

4. In the case of complex products or objects, how can I identify the correct product hierarchy with all SVHC substances included?

You can refer to the IMDS tree structure to identify the correct product hierarchy. In the case of multiple electronic components, it can be a daunting and time-consuming task to have numerous SVHCs in multiple nodes at levels 10 or higher. All such hassles can easily be avoided by partnering with an experienced regulatory solutions provider like APA Engineering.

5. How do I proceed with creating the right SVHC in the case of complex objects? Do I need to manually create all the substances for declaration while creating the article dataset?

To create the right SVHC for complex objects, tree structure should be used and retained as well. You don’t have to manually create all the substances for declaration. You can use the SCIP candidate list package published by ECHA for getting ahead of the curve.

But how do you first register your company to prepare and submit a SCIP notification? Did it occur to you? Well, you need an ECHA account for that. For carrying out this process, you can explore two alternatives:

● Create a new ECHA Account as described in the chapter “How to sign-up for the first-time” of the ECHA Accounts Manual.

● Use an existing ECHA Account. If you need to create a separate account for administrative purposes, i.e., create different accounts based on regulatory scope, special attention needs to be given before you decide using an existing ECHA account and submit notifications to the SCIP database.

6. What is the importance of a legal entity in the process of SCIP submission?

A legal entity is of much importance in the SCIP submission process. To begin with the process, each company is required to create an ECHA account by assigning a legal entity and then subscribe to ECHA cloud services. In this context, a legal entity can represent a single person authorised to manage commercial contracts or a large business organisation/structure.

7. While making a SCIP notification, what are the important steps I should follow?

The following documents are pertinent to file in, while making a SCIP notification:

● Identifiers

● Categorisation

● Characteristics

● Safe use instructions

● Concern element information

You can make use of information published by ECHA titled ‘Preparing a SCIP dossier’ to understand in detail about all the other essential steps to make a SCIP notification. Click here for a detailed outlook on this.

8. What is the recommended option to select a primary article identifier for automotive parts?

The part number is highly suggested by experts worldwide to be selected as a primary article identifier. This applies to automotive parts as well.

9. Why is the information requested at an article level?

According to the legal provisions of Article 9(1)(i) of the Waste Framework Directive and of REACH Article 33(1), the information to be provided to the SCIP database should be on the article, as such or in a complex object, containing the Candidate List substance.


Are you now beginning to wonder if there is a way to automate the entire submission process and save time? The answer is YES. ECHA offers an option called system-to-system (S2S) through which automation of SCIP submission is possible by linking any third party/in-house software with the SCIP submission portal. A third party can also create an ECHA account and submit data to the SCIP database on your behalf.

If you are stuck at any of the stages in submission or have more questions, get in touch with APA Engineering right away. We have assisted many companies with end to end compliance management solutions and collaborate with businesses in streamlining the SCIP submission process, along with many other compliances. Get in touch with our industry experts today to know more.



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.