ECHA (European Chemicals Agency) has very recently introduced the world to its new SCIP Database. SCIP Database, or Substances of Concern In articles, as such or in complex objects (Products) Database was introduced for industries and companies on September 9, 2019; and will come into effect from January 2021 onwards, where companies have to provide information to ECHA SCIP Database. This information is targeted towards industries that supply or export products or articles containing Substance of Very High Concern, or SVHC on the updated list of SVHC by ECHA. If the concentration of SVHCs is equal to or above 0.1% by weight in any products, the company must update and record this information in the ECHA SCIP Database from 5th January 2021.

Established under the revised Waste Framework Directive by the European Union, ECHA has been tasked with collecting information from industries across the EU market to enhance the safe practice of SVHC.

Applicability of ECHA SCIP Database

Any and all distributors, production companies, and assemblers that work in the EU market supplying any articles containing the defined SVHC concentration are required to document the information of the said article on the ECHA SCIP Database. Moreover, any importers who wish to carry out their business on the European soil are also required to adhere to the ECHA regulations, and should register and document all the required specifics of the products or articles they’re importing on the SCIP database.

Note: REACH has a set definition of an “article”, which characterizes it as an object that is molded into a specific shape, design, or surface which helps in determining the object’s function to a much greater extent than is done by its chemical composition. Some examples of articles are newspapers, magazines, clothing, furniture, jewelry, etc.

Objectives of the new ECHA SCIP database

The SCIP database was created by the EU to strictly monitor the usage of SVHC elements in products. The three main purposes of implementing this database are:

1.  Making the operators and distributors completely aware of any possible threat the materials they are dealing with can pose is the primary purpose of the ECHA SCIP database

2.  Safe disposing of the articles by ridding them of the hazardous SVHC before they are recycled or reused

3.  Aiding the consumers in knowing how to dispose of articles containing hazardous substances by explicitly mentioning the relevant information about the SVHC on the product descriptions

Information required for registration with SCIP database

The following pieces of information must be provided to the ECHA REACH registered substances database to distribute the product anywhere in the European market:

●  Pictures of the articles along with their characteristics

●  Location, concentration, and name of the SVHC present in the article

●  Any instructions relevant in handling the hazardous substances and safety precautions the customers can take

Requirements for the Article:

1.  The name, picture, and characteristics of the article, including color, length, and volume for the process of visual identification by authorities

2.  Inclusion of Primary Article Identifiers like the catalog number, GTIN, part number, EAN, etc

3.  As understood by the description of the CN/TARIC code, the article must be categorized and reported in a defined category

4.  Full disclosure of the information pertaining to the assembly or the production of the article, and if it was done in the EU or any other part of the world

5.  Instructions relevant to the safe using of the article, along with detailed instructions on how to disassemble the said article

Registering Complex Products – What to document:

1.  Listing out all the linked articles that were used as the part of production in the complex product

2.  Specifying the number of occurrences of the linked article in the complex product

What to document for Concern Elements and Substances:

1.  Include the EC, CAS numbers, and name of the substances from the Candidate List.

2.  Reporting the range of concentrations of SVHC substances and other substances in the article

3.  Identifying the Material or Mixture Category of the substances in the article

ECHA SCIP Database Prototype

A prototype version of the ECHA SCIP database was introduced by the EU in January this year for testing. The purpose of this prototype is to make the companies acquainted with the reporting, registering, and submission process, which will go live on 5th January 2021.

There are two elements that are included in this prototype, which are :

1.  Data preparation in IUCLID – The SCIP notification, initially, will only be available in the IUCLID cloud, and will be distributed amongst companies through the ECHA Cloud service. For companies looking to gain access to this SCIP prototype, they would have to get an ECHA account and a subscription to the IUCLID cloud service. Here, data will be prepared by the companies in a defined format, and sent to ECHA for submission.

2.  Data Preparation from the IUCLID 6 (Offline) – Companies can also download and use IUCLID 6 software to receive SCIP notifications offline. IUCLID version 6.4 was made available to companies and the public from April 2020.

After these processes are taken care of, the data submission can be done by companies using the ECHA Submission Portal. This portal was created by ECHA as a tool for companies, which makes the submission process seamless. All the information via submissions that are uploaded in this portal is then automatically transferred to the SCIP database.

Note: Any SCIP notifications that are submitted using the SCIP database prototype are to be considered as “Test Data”, and will be deleted later

System-to-system service is an alternative method, through which, companies will gain the ability to submit their SCIP notifications in an automated manner. The process for attaining this service is to get approval from ECHA to link the company to the ECHA Submission Portal, which would link the portal to their own systems. After this, the API specifications declared by ECHA should be implemented on the company’s systems, which will then carry out the SCIP notification submissions from the company’s network domain automatically.

Conclusion

Now that you are aware of all the new norms in the ECHA SCIP database you can consult APA Engineering for a seamless transition in the regulations and reporting of your products to carry out business in the EU. Keep your company safe by following all the compliances, and report correctly about your products.