A successful webinar on SCIP compliance was conducted on 4th Nov across the US and Europe regions. The compliance leaders from automobile, electronics, the medical industry at various levels, participated and gained insights into the new SCIP regulations.
Challenges in manual SCIP submissions
Automating SCIP submission using APA’s ‘GreenCheck software’
Live demo of SCIP submission in ECHA cloud
SCIP “Go Live” action plan template
Can we directly consider the amount of SVHC reported from Full material declarations?
No, the amount of SVHC reported will be at material level in full material declarations like IMDS, IPC 1752A Class D xml. For SCIP, the reporting has to be done at article level, not at material level. So need to calculate the SVHC amount at article level & check whether it is exceeding 0.1%.
How did you identify the SVHC substances for automobile parts?
Substances breakdown information for automobile parts are available in IMDS portal and IMDS has the analysis option to find the SVHC contained parts. But it will give you the complete list of parts with SVHC presence irrespective of reporting limits (>0.1% at article level).
How can we get the substances break down for non-automobile parts?
Need to contact the supplier for getting the full material declaration or collect the SCIP related info using custom templates. Alone with REACh Compliance certificates (CoC), we won’t be having the necessary information to make the SCIP submission.
How do I update a SCIP notification?
For updating your SCIP notifications, you need to:
a) Update the information included in your dataset
b) Validate & create a new dossier - The primary article identifier (type and value) in the dossier needs to be the same.
c) And finally make the submission using the same ECHA account.
ECHA submission portal will consider it as an update if dossier contains the same primary article identifiers & legal entity details.
As per ECHA guidelines, is it mandatory to provide safe use instructions for all my products while making SCIP declaration?
Yes, for SCIP notification, it is mandatory to provide the Safe use instructions for all your products. But in case if you don’t have any specific instructions to provide apart from communicating the SVHC presence, the below mentioned generic statement can be selected to meet the requirements “The identification of the Candidate List substance is sufficient to allow safe use of the article throughout the whole life cycle including service life, disassembly and waste/recycling stage”.
Through making SCIP submissions, am I fulfilling REACh obligations stated under Art33 & 7(2)?
No even after making SCIP notifications, you still need to comply with REACh communication and notification obligations since these requirements differ on their legal base and objectives. A supplier of an article which contains SVHCs in a concentration above 0.1% (weight by weight) must provide enough information to allow the safe use of the article to customers, i.e. industrial or professional users and distributors, according to REACH Art. 33(1). Consumers can request similar information. The supplier of the article has to provide this information within 45 days, free of charge. Producers and importers of articles have to notify to ECHA the SVHCs present in their products, if the weight of substance is exceeding 1tonne, according to REACH Article 7(2).
When do I need to update my SCIP notification?
An update for SCIP notification is required in below scenarios:
a) when a substance present in an article (in a concentration above 0.1% w/w) is included in the Candidate List after 5 January 2021
b) Change in the composition of articles containing Candidate List substances
c) Request from a Member State authority to submit additional information to a SCIP notification, if the submitted information does not meet the SCIP requirements
d) If an already notified Candidate List substance present in an article has been substituted by a safer alternative – update on voluntary basis
Can a third party submit a SCIP notification on my behalf?
Yes, third parties can make SCIP notification using foreign user concept. For this, the third party need to create an ECHA account and share the username & legal entity UUID details to 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.
A comprehensive ‘SCIP preparation checklist and a step by step action plan template has been created by our experts. If you wish to get a copy, please send a mail to firstname.lastname@example.org