How to run a ‘SCIP Pilot’ before actual submission?

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A successful webinar on SCIP compliance was conducted on 15th Sept 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.

Topics Covered during the session

  • 1

    Pre-requisites and preparatory activities needed

  • 2

    Techniques to achieve SCIP compliance

  • 3

    Top 5 Challenges to overcome in implementation

APA experts answered key questions asked by compliance leaders during the webinar

From where can I understand & learn about SCIP reporting obligations?

ECHA has provided all relevant guidelines in form of PDFs & webinar recordings on their official website under the menu “SCIP Database” https://echa.europa.eu/scip-database

What can be the preferable choice for selecting a Primary Article identifier while making SCIP submission?

The most preferable choice will be part number which will commonly be mentioned in REACh certificates & Full material declarations

What is the Article category and how it should be selected?

The article category is used to identify an article or complex object according to its function or use. It’s the key to identify the impacted waste streams and care should be taken in while selecting it. IUCLID has its reference linked to Combined Nomenclature (CN) or TARIC database which is readily available in the search window

What is called a legal entity? How it is important for making a SCIP submission?

A legal entity may represent anything between a complex business structure and a simple organized business (e.g. corporation, company, organization) or a single natural person capable and having the right to engage in contracts or commercial transactions. To start with the SCIP submission process, each company needs to create an ECHA account assigning a legal entity & then subscribe to ECHA cloud services & ECHA submission portal.

Is there any way to automate the SCIP submission process?

Yes, ECHA is offering an S2S (system-system) option through which automation of SCIP submission is possible by linking any third party/in-house software with the SCIP submission portal. Please contact APA for solution offerings towards the same.

If we go for manual SCIP submission, what are the challenges & concerns?

The main challenges involved will be in identifying the parts for SCIP reporting, collecting the data from the supply chain, and creating the data in IUCLID as per ECHA SCIP format. If you have a huge volume of parts expecting SVHC content, it will take months and may cause a problem in meeting your legal requirements.

Are there any validation rules to oblige with while making SCIP notification?

Yes, there are two types of rules i.e. Business & Quality rules. Violation of business rules leads to rejection of the submission. In case of violation of any quality rules, submission can be done, but the duty holder will be receiving notifications requesting to improve the quality of the submission. All the rules are available in below link: https://echa.europa.eu/documents/10162/28976980/validation_rules_for_SCIP_notifications.pdf/5323b9e5-4c15-7cad-3bcc-5f4994d407bd

While trying to create an Article dataset in IUCLID, I am not able to find any candidate list substances to refer to. Do I need to create all the substances manually for declaration?

No, ECHA has published the SCIP candidate list package (I6Z format) on their website https://echa.europa.eu/candidate-list-packageWe can import this package to our IUCLID instance before starting with the process.





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