If importing via a distributor, whose responsibility is to provide SCIP information?

SCIP obligations fall on the shoulder of the distributor i.e. importer. Non-EU suppliers are not falling under the scope of SCIP

IMDS release 13 will be available in Q1 2021. How APA can help analyze the impact of new attributes from the latest release?

As per IMDS newsletter, SCIP reporting will be supported using below features

• Introducing SCIP attributes like Article category/Production in EU/Safe use instruction
• Transfer of MDSs one by one to SCIP database Using our in-house software “Greencheck”, we complete your SCIP requirements with IMDS PDF report as a minimum requirement from your end

When can we start submitting the data for SCIP? Do we need to wait until Jan 2021 or it can be done ahead of it?

By the end of October 2020, SCIP database will be open to receive a notification to comply with the legal duty

Can you help to highlight the key features of SCIP and how it is different from REACH?

The main differences lay in the declaration requirements. In case of SCIP, the requirements are much more complex compared to REACH. As per Article 33 of REACH regulation, all suppliers of articles containing any SVHCs above 0.1% (w/w) should communicate the substance name and available safe use instructions throughout their supply chain. And a single declaration can be done on product-level basis. SCIP submission should be made at the article level, which means separate article dossiers need to prepared with the included SVHCs linked under the complex object

What are the typical challenges a company will face while complying with new SCIP regulations?

The typical challenges include:

• Identification of SVHC containing products from your portfolio
• Data collection from supply chain to fulfil the requirements
• Figuring out the adequate article category/material category from a huge picklist
• Selection of best practices for meeting SCIP obligations (Manual/Automated)

Does APA have any automation software to manage SCIP compliance processes?

Yes, APA is having an In-house software named Greencheck supported with SCIP module which enables automated SCIP submission for your products