The obligation to report products that are put on the EU market and contain of SVHCs (Substances of Very High Concern) of > 0.1% by weight on article level to ECHA’s SCIP database is now almost 4 months old. So let’s have a look at how reporting has worked so far.
Based on ECHA’s statement after approx. 3 months of reporting, the number of dossiers was around 10 million submitted by approximately 3,600 companies. With industries’ estimations for the numbers of dossiers being in the order of magnitude of around 1*1012, it seems there is still a lot more to come. What have the issues been that have prevented further dossier submission up to now?
Challenges for reporting of SCIP dossiers
Some of the challenges for initial reporting of SCIP dossiers have been purely technical, starting with the database itself being unreachable at times. This in turn has caused quite a number of dossier validation failures, as reported by ECHA in their statement on.
Then there were additional factors throwing a spanner in the works for all companies bringing large and complex products onto the market – a limitation to a maximum of 1000 components per dossier – fully in effect since April 2021.
All in all these constraints required quite some ingenuity and hands-on work to fulfil SCIP reporting obligations. Some key steps were:
- Leveraging existing information on product composition and using the option of “jokers” for mandatory field values (such as “no data” for Production in EU statement or the broadest concentration band for the concentration of SVHCs).
- Mapping existing information, e.g. for material categorization to ECHA’s picklist values
- Compression of BOM structures of large products to a meaningful and manageable layout
- Leveraging options to simplify reporting like referencing and Simplified SCIP notification
Key product features of the SCIP Database Connector
Working hand in hand with our customers, iPoint has been working continuously on our SCIP solution to support SCIP reporting. Key product features include:
- Automated collection of product composition information and SVHC analysis via iPoint Compliance module simplifies identification of SCIP relevant products
- Setting of default values for several mandatory SCIP data fields allows for fast processing
- Automated mapping of VDA classes (if used) to ECHA’s material categories in alignment with automotive industry agreement
- Various BOM compression settings to report meaningful structure and stay within the limit set by ECHA.
- Further option of referencing own sub-component dossiers to reduce BOM size
- Easy option for Simplified SCIP reporting to handle reporting obligations of all legal entities in one place
- Detailed information on submission status to track dossier and handle database downtimes
- Easy overview of products and submissions for internal reporting or passing on submission information to customers
- And, of course, bulk submission of dossiers via the system-to-system interface.
Watch the video – Dr. Angelika Steinbrecher talks about the Challenges and Approaches to SCIP Reporting at the CLEPA Event 2021