[EXPERT WEBINAR]

SCIP Dossier Submission - Unfolding & Mitigating Roadblocks

Watch Recording

A successful webinar on SCIP compliance was conducted on 11th February 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

    SCIP data requirements and challenges

  • 2

    Practices that help SCIP dossier submission faster and smoother

  • 3

    Automation to accelerate SCIP compliance

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

What if I am an article manufacturer outside the EU and supplying to the EU, who is responsible for SCIP submission?

EU importer has to do the SCIP notification or your customer may ask for SCIP data in any format with SCIP mandatory attribute details

Whenever a new SVHC is added how much time is given 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

I have multiple(16) legal entities in the EU, can I submit a single dossier or 16dossiers?

You have to submit 16dossiers, however, you have an option not to re-use the data using the SSN referencing concept

I have a manufacturing facility in the UK and sell it across the EU, what are the obligation?

Post-Brexit UK, doesn’t need any SCIP dossiers. Your EU importers must register the SCIP dossiers and you have to provide them the relevant details

Does packaging require SCIP dossiers?

As per WFD, the packaging is also considered an article and it requires a SCIP dossier

Do suppliers have to provide specific concentrations or is it just the range that is needed?

Both are fine because SCIP accepts ranges of concentration

Should I worry 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.

Do we have any penalties if we miss SCIP due date?

No penalties published by member state at this juncture. If a company continues to sell in the EU without SCIP notification, it is a non-compliance and it is up to the individual company to decide on its risk

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A comprehensive ‘SCIP dossier checklist’ have been shared with the attendees. If you wish to get a copy, please send a mail to compliance@apaengineering.com