In less than a month, companies manufacturing, importing or distributing products in the EU will need to comply with SCIP. In the meantime, though, there are many questions surrounding the preparation and submission process of SCIP notifications and what the SCIP database actually is.
Built by the European Chemicals Agency (ECHA), SCIP is the new database for storing safe-use information on substances of very high concern (SVHCs) in articles as such or in complex objects (i.e., products). It’s established as part of the EU Waste Framework Directive (WFD) 2008/98/EC and adds to existing reporting requirements managed under the REACH Regulation. The database is designed to gather the information required for achieving the objectives of WFD Art. 9 (2).
The SCIP database will ensure that the information on articles containing Candidate List substances is available throughout the entire lifecycle of products, components and materials, including at the waste stage. The information in the SCIP database is then made available to waste treatment operators and consumers, as well as to other actors in the supply chain, NGOs and authorities.
A SCIP notification is a dossier having the i6z extension. It is prepared by the product producers or other duty holders and submitted to ECHA. It provides information on the presence of SVHC in articles in a concentration above 0.1% w/w. The dossier must include all the relevant information in XML files representing and corresponding to the various documents. It must also include a manifest file containing a table of contents with all the data files and documents that are available in the dossier. Generally speaking, the information must consist of elements that allow:
A SCIP notification of an article as such represents a dataset that includes in the concern elements section the information related with the Candidate List substance present in the article.
A SCIP notification of a complex object is built in a primary dataset that incorporates one or several link components datasets of either an article as such or another complex object component that includes the information related with the SVHC present in each element of the complex object.
The SCIP notification format must be XML-based compatible with IUCLID. Thus, the following data types are allowed: text (single-line, multi-line and text area), picklist (single), multi-select list, check box, numeric, decimal, and attachment. Once submitted, the SCIP notification cannot be re-submitted.
Companies must be ready to submit their SCIP notification on January 5th, 2021.
Duty holders can use one of the following ways to start preparing a SCIP notification:
Generally speaking, any company in the scope of REACH is in the scope of the EU WDF and must comply with SCIP. This means that the following economic operators will be responsible for submitting information on the SVHCs into the SCIP database:
Producers selling their products outside of the EU won’t be required to comply with SCIP and submit information to ECHA. The same applies to retailers and other supply-chain actors who supply articles directly to consumers.
In cases where a supplier is based overseas but has several EU importers, only the first importer is responsible for submitting a SCIP notification on their behalf.