Case Study Successful Scip Dossier Submission Webinar | APA Engineering

[CASE STUDY WEBINAR]

Successful SCIP Dossier submission by EU and non-EU companies within 15 days

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A successful case study webinar on SCIP compliance was conducted on 25th March across the US and Europe regions. The compliance leaders from automobile, electronics, the medical industry at various levels, participated and gained insights into the obligations on SCIP regulations.

Topics Covered during the session

  • 1

    Overview of SCIP submission process for EU and non-EU region

  • 2

    Case Study- European and Non-European Company

  • 3

    Obligations for EU and Non-EU companies

  • 4

    Possible Challenges and Best Practices

  • 5

    Tools and Techniques used to accelerate the process

  • 6

    Latest updates on SCIP and its impact on business

Our experts answered all the questions asked by compliance leaders during the webinar.

As a non-EU entity, but has a parent company in the EU, any suggestions to submit dossiers to the SCIP database? Appreciate it if you could recommend creating a legal entity for this situation. Any such experience?

The EU company has to create the ECHA log-in and make the SCIP submissions. Being you are in non-EU, you need not worry unless you supply parts to the EU

Can we use the IMDS system to submit SCIP dossiers. Could you elaborate more, please?

Currently IMDS is in release 12, SCIP features are expected to be rolled out in release 13.

Is it accurate to say that the SCIP dossier is required for each product, e.g. for an automotive company this would be a dossier per VIN and NOT by model type?

Yes, if your company sells assemblies/modules and spare parts, it is required to have SCIP numbers for Assemblies/modules and spare parts separately. It is not required for every individual product unless you sell them in the EU market.

Can you confirm that a SCIP dossier is only required when the SVHC included in a product is more than 0.1%w/w?

SCIP dossier is needed only if SVHC is greater than 0.1% w/w concerning the immediate article (not material)

What should we do if a new SVHC is added? And how much time is given for us to update the SCIP dossier of the company?

As of today, there is no defined time in the waste frame directive. But normally as a common practice, 6months to 1year may be the expected time frame

Should I concern if the EU importer is not requesting SCIP Dossiers from a non-EU manufacturer?

Yes, you should worry. if the importer is selling the products after 5th Jan 2021, the SCIP dossier is required to be submitted by the EU importer in this case.

Can you summarize the Non-European companies' obligations?

Non-European company does not have any legal obligations, however, if your product lands in the EU through your customer, your customer might come back and ask for SCIP details, as the customer introducing to the European market need to meet the SCIP LEGAL compliance. In such cases, they might come to you for SCIP details. The whole communication between you and your customer shall be minimized if you share a SCIP dataset instead of a traditional excel/email, provided if you have SVHC substances on your part. It is strongly encouraged to create an ECHA SCIP account for you even if you are out of European Union. In simple words, a Non-European company may have a customer obligation to supply the SCIP mandatory details

I have multiple plants in the EU, Is it required to submit from all the plants or submit at the corporate level?

As per the current rules, every legal entity is required to submit a SCIP dossier. For example, if part number 1234 is manufactured from 3 plants in the EU, you have to submit the SCIP dossier for part 1234 from all 3 plants separately. However, you can simplify the submissions using Simplified SCCIP Notification (SSN)

How can I update the SCIP dossier?

If any SVHC substance is added or removed, you can open the SCIP submission, keep it in edit mode, make the changes and submit. As long as the primary identifier i.e., the part number is not changed, it retains the SCIP number. The beauty is if your SCIP number is shared with your customer already and if they link it to their SCIP dossier, it gets updated automatically. You need not share the updated details again with the customer.

Can a third party like APA submit a SCIP notification on my behalf?

Yes, a third party like APA can make SCIP notifications using foreign user concepts usually. For this, the third party needs to create an ECHA account and share the username & legal entity UUID details with the duty holder. Using the same credentials, the duty holder can introduce the third party as a foreign user to their account and make submissions accordingly.

For REACH, I have been collecting declaration letters from my suppliers, can I do the same for SCIP?

Yes, you can but please remember the letter that you get from the supplier is valid as on the date in the letter. If the SVHC list gets updated, theoretically, you have to get the declaration letter again. To avoid repetitive work, APA recommends collecting the Full material declaration using software for a sustainable process.

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If you wish to get a copy of the ‘SCIP dossier checklist’ or ‘SCIP Template’, please send a mail to compliance@apaengineering.com