Complying with notifications for Substances of Concern In Products (SCIP)

What is SCIP?

The SCIP database shares information about Substances of Concern In Products maintained by the European Chemicals Agency (ECHA) and used to communicate information on the presence of Substances of Very High Concern (SVHC) at all stages of the lifecycle, including end-of-life waste handling.  The overall objective of SCIP is to reduce the loss of information during waste processing on the presence of SVHC as Europe progresses towards a circular economy.

Submitting notifications to ECHA’s SCIP database became a requirement from 5 January 2021 under the Waste Framework Directive (WFD) which sets the regulatory framework for the implementation of the SCIP database to demote the production of harmful products in support of creating a safer circular economy across the entire product lifecycle – from use to disposal. The database makes it easier to access information on hazardous substances within products placed on markets within the European Economic Area (EEA) . These substances, found in everyday consumer products, can have serious and often irreversible effects on humans and the environment, and include substances having at least one property is:

• Carcinogenic (Article 57a) 
• Mutagenic (Article 57b) 
• Toxic for reproduction (Article 57c) 
• Persistent, bioaccumulative and toxic / PBT (Article 57d) 
• Very Persistent and very bio-accumulative / vPvB (Article 57e) 
• Endocrine disrupting properties (Article 57(f) - environment) 
• Endocrine disrupting properties (Article 57(f) - human health) 
• Respiratory sensitising properties (Article 57(f) - human health) 
• Specific target organ toxicity after repeated exposure (Article 57(f) - human health) 
• Equivalent level of concern having probable serious effects to human health (and/or) the environment (Article 57f)

The SCIP database contains information on over 10 million articles on the EEA market containing SVHCs and can be publicly searched by the article name, product category, chemical name or material type, providing information on safe use, handling and disposal as supplied by the notifier.

Who is responsible for notifying to the SCIP database?

The SCIP database affects some of the world’s largest industry sectors, including electronics, automotive, consumer goods including furniture, and agriculture. Suppliers, manufacturers or importers of products placed on the market in the EEA that contain SVHCs above 0.1% weight by weight are required to submit notifications to the SCIP database. 

The below flowchart can give you an indication of if you are required to submit SCIP database notification:

The amendment to the WFD is in addition to the existing requirements under REACH legislation, wherein any article containing over 0.1wt% SVHC must have its presence communicated to recipients. SCIP notifications, for impacted articles, must be submitted within 6 months of an SVHCs inclusion on the Candidate List. 

ECHA publish the information as received, but it is the duty holders obligation for maintaining compliance and ensuring they are up to date with their obligations under REACH and the WFD. This includes notifying if the SVHC is subsequently removed from an article. It is not possible to delete a SCIP notification once an SVHC is no longer present, as products can still be appearing in waste processing decades after they were last placed on the market. 

Which products require SCIP notification?

Any article containing a SVHC, with a concentration of 0.1% weight by weight or above, requires a SCIP notification. Additionally, any complex object or product which contains article(s) requiring SCIP notification must also be notified. Where the product is made from more than one article, the 0.1wt% SVHC rule applies on a per article basis not against the overall complex product weight. 

The required information for a SCIP notification includes:

• Information on the identification of the Article
• Name, concentration range & location of the SVHC(s) within the article
• Information on safe use of the article, including proper waste management. 

Dossiers are checked on a pass/fail basis before being published on the database. 

What does SCIP mean for your organisation?

If your organisation produces, assembles, or distributes SVHC within the EEA you must notify to the SCIP database from an EEA registered legal entity. Downstream users have an obligation to also notify, for which there is a simplified notification process linking them to the original notifier, but retailers that supply to consumers do not. 
It is therefore key to ascertain if you have SVHC in your products. One of the biggest challenges for industry are faced by those organisations in a product assembly role, who may source articles for their complex products from numerous global suppliers and require information on presence of SVHCs from each supplier for each article. Some complex product SCIP notifications can reference 100’s or even 1,000’s of individual SVHC containing articles. 

Support with SCIP notifications

Notifying to the SCIP database is a complex legal requirement. Our chemical experts can support you to maintain compliance and access to markets across the globe by combining their in-depth knowledge of global supply chains and regulatory experience to understand your obligations worldwide and prepare your organisation for any future changes.

Designed to reduce the time, expense and resource invested in maintaining compliance, our solutions support you through the notification process: from collecting the data, registering your legal entity with ECHA, and completing the notification on your behalf, Ricardo can provide guidance and assistance at every stage.

We understand that no two companies are the same, and neither are their products. Through evaluating your product portfolio and identifying your compliance requirements, we can offer tailored advice on how to reduce your regulatory burden through grouping, referencing and simplified notifications.

Our Horizon Scanning service can be used in combination with SCIP solutions to alert you of regulatory changes impacting your portfolio, and our chemical regulatory team can help you make informed decisions to enable compliance with the ever-changing regulatory landscape, supporting your business today for a more sustainable future. 

Contact our team today for assistance with how to make submissions to the SCIP database or any other regulatory legislation.