ECHA has recently published detailed information requirements for the SCIP database, which entails increased obligations for companies that market an article containing an SVHC above 0.1% in the EU. iPoint is already involved in working groups with ECHA, especially the SCIP IT User Group. As a official member of the IT user Group we provide input on the development of the system, share our ideas for improvement, analyse different scenarios and help to identify the areas where extra attention is needed in order to provide adequate support/guidance. Our goal is to develop a connector for the automated information exchange between ECHA’s SCIP database and iPoint Compliance.
ECHA develops the SCIP database
With the revision of the Waste Framework Directive (EU) 2018/851, Article 9, the European Chemicals Agency ECHA was tasked with the implementation of a database collecting (and making available) information on articles containing Substances of Very High Concern (SVHC) above 0.1% by weight as specified by the Candidate list. Ever since this became known, companies have raised concerns over this increase in reporting obligations.
ECHA has now published a document detailing the information requirements of the so-called SCIP database. Companies placing an article containing an SVHC above 0.1% on the EU market are required to submit information from January 5th, 2021 onwards. A first version of the SCIP database will be available one year prior to this date.
SCIP stands for Substances of Concern In articles, as such or in complex objects (Products). Although the SCIP acronym encompasses “products”, ECHA explicitly avoids using the term in the description of its information requirements limiting it to “articles”. Mixtures and substances are not under consideration, information obligations exist for articles as such as well as articles in complex objects. (For a more detailed description see ECHA’s Guidance on requirements for substances in articles.)
Three key information constituents have to be provided
- article identification
- safe use information and
- identification, location, and concentration of the Candidate list substance(s) contained
The first section requires a description of the article or complex object with seven out of 14 fields being mandatory. They include the categorization of the article or complex object based on a harmonized list as well as the safe use information. However, the remark „no need to provide safe use information beyond the identification of the Candidate List substance” can be selected here.
In the second section, information on the so-called “concern element” needs to be given, i.e. the article within a complex object containing the substance of concern above 0.1%. Out of the eight categories, five are mandatory. One piece of information that has to be provided concerns the category of material or mixture containing the SVHC, with the aim of identifying relevant material-based waste streams.
ECHA will ensure protection of confidential data
An interface between ECHA’s SCIP and iPoint Compliance facilitates data submission
To simplify matters for companies submitting information, ECHA is looking into a) permitting referencing an already submitted upstream notification of the same article as well as b) a solution to provide for system-to-system submission, with an option to connect supply chain tracking tools to ECHA’s database and thus avoid manual work. ECHA’s IT solution is based on the IUCLID system with different access options.
Although the SCIP database and its information obligations presents manufacturers with yet another duty, its fulfilment will be straightforward for all of those who already have an integrated compliance system in place such as iPoint Compliance (includes former iPCA and Material Compliance). Furthermore, iPoint is directly engaged with ECHA via working groups focused on developing a suitable interface which allows the automated exchange of the information between ECHA’s SCIP database and iPoint Compliance.
Collect, analyze, report, and evolve data with iPoint Compliance
Paired with the modular iPoint Compliance, which offers the option to collect, analyze, report and evolve product information throughout the supply chain, you have all information readily available to comply with substance regulations like REACH and also to fulfil SCIP-related information obligations.
Of course this data can also be used to analyze and report with regards to further obligations such as REACH Article 7(2), REACH Art. 33 (1), monitoring of REACH Annex XIV and XVII, ELV, RoHS, California Proposition 65 and others. It can also support a company’s evolvement towards sustainability and carbon neutrality. To ease communication to the public on the basis of a REACH Article 33(2) request, iPoint is also active in the development of the supply chain communication tool under the LifeAsk REACH project, which offers consumers to request information on the SVHC content of a product via the AskReach-App.
iPoint participates in ECHA’s SCIP Database Kick-off meeting
Last week saw the kick-off meeting for stakeholders of the SCIP database held by the European Chemicals Agency ECHA. The agency gave insights into the database set-up with possible access points for data submission either via a web application or via an interface to the IUCLID software. It was clearly stated however that there will be no export of data from the interface as well as no bulk upload of data. iPoint will continue to participate in the regular stakeholder meeting with ECHA. Once more details are known on the SCIP database prototype, iPoint is going to work on a way for iPoint Compliance customers to fulfil their reporting requirements in an easy and effective way.
Results from the ECHA workshops and new SCIP website launched
Since our last update on the SCIP database, work has progressed further. Not only have we participated in ECHA’s workshop in Helsinki in November and in the IT working group meeting, ECHA has also launched a new SCIP website.
We took home quite some information on the SCIP database from the meetings.
- ECHA is going to implement the SCIP database (cloud based, local and interface) step-by-step with an agile approach. Within Q1 2020 it will be possible to create a dossier but not submit it finally. A first version of the interface (called S2S, System to System) will be available in October 2020.
- There will be user manuals, step-by-step guides and as well as FAQ on their website.
- Independent of which interface the companies are going to use a registration within the ECHA portal on a legal entity level will be required. But companies could delegate the submission either to their mother companies or to software vendors.
Furthermore, ECHA has given a glimpse into their ideas for the validation rules. The validation checks will cover approximately 20 rules, covering the mandatory fields, some logic checks on the optional fields as well as checks on the dossier to cover the option for updates. In addition to that, ECHA has stated, that they will publish an “exhaustive list” of SVHC substances for the description of the “concern element” within the SCIP database. They strongly recommend to use this list, provided as a IUCLID readable format as well as a .csv file, for SCIP dossier submission. We are looking forward to the next meetings, where ECHA will give more insight into their view on the solution for a system-to-system submission.
Since December 4th, ECHA has put a new SCIP website online, including more information for duty holders and users of the SCIP database information. They have included an extended section providing documentation, workshop information and the tools for SCIP notification.
iPoint will continue participating all the SCIP meetings and further focusing to provide a solution for the customers
Be prepared for the upcoming challenges of the SCIP datebase