EU Commission not empowered to postpone SCIP
On September 21, 2020, 40 EU and non-EU industry associations asked the European Commission to postpone the date for suppliers to start fulfilling their obligation of submitting information to the SCIP database beyond 5 January 2021.
The EU Commission declares that they understand the challenges that the companies are facing due to complex supply chains, the pandemic crisis and additionally the upcoming requirements set by Article 9 of the Waste Framework Directive (WFD). Yet the EU Commission is not empowered to modify neither the reporting obligation nor the date of January 5, 2021.
They further state that the EU Commission and ECHA have made every effort to achieve compliance with the legal obligation within the two-year time frame. ECHA has provided detailed information requirements for the SCIP database and in its SCIP format, as well as further guidance and supporting information, in a timely manner. The first version of the SCIP database has been available for testing since February 2020 and the SCIP database was opened for submission of notifications at the end of October, two months in advance.
There are still two months left to get prepared and find a solution to the reporting obligation for the SCIP database, which will apply from 5 January 2021. The EU Commission encourages companies to make every effort that is possible within these limits.
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Get the answers on the TOP 40 frequently asked questions
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.
First glimpse at the SCIP database
During last week’s ECHA IT working group meeting iPoint’s experts had the chance to get a first glimpse at what the SCIP database will look like. With these first impressions, we are eager to be able start testing on it this week, although it has become clear that any data submitted in the initial stage will not be re-usable for final submission.
In addition, ECHA has again strongly recommended to make use of an interface for a system-to-system solution for the upload of a large number of data sets and / or multiple complex objects. This has spurred us on to continue on our path of development of a solution for SCIP submission easing both the analysis of submission obligations as well as the handling and upload of large amounts of data.
Stay tuned for further information on iPoint’s support for your SCIP database submission.
SCIP Database test version available
On Monday, February 17th, 2020, the long-awaited release of the test version of SCIP database – short for Substances of Concern In articles as such, or in complex objects (Products) – was released. After almost a year of seeking funding for development and intense development efforts by the European Chemicals Agency (ECHA), a test version is now accessible via ECHA’s SCIP website. As a prototype version, it will not yet provide the full functionality of the final SCIP database, which is expected to be released by October 2020. But it will still be an option to test how the final submission will be. ECHA will continuously update the prototype with new functionality for testing until it goes live.
SCIP database alpha testing
In our webinar “How to get ready for ECHA’s SCIP database“ we were excited to be able to give you an impression of the system-to-system solution that iPoint is working on to allow for a bulk upload of data to ECHA’s SCIP database and share our approaches of an easy analysis and reporting of data.
If you want to learn more about iPoint’s software solution for SCIP and are interested in taking one of our 10 seats for alpha testing, please contact firstname.lastname@example.org
SCIP database and RoHS (2011/65/EU)
One interesting issue that came up in the Q&A session was whether there are requirements of a REACH notification along the supply chain (REACH Article 33(1)) and SCIP reporting (based on the Waste Framework Directive) for the RoHS-exempted lead.
In case you are operating under a valid RoHS exemption using lead in concentrations above 0.1%, this will mean that you will nonetheless have to notify your supply chain on the presence of an SVHC above 0.1% according to REACH Article 33(1) and also report the article (or complex object) to SCIP database from January 5th, 2021.
However, a remark has to be added to this general statement: RoHS and REACH differ in their reference point for the calculation of the concentration of a substance of concern (homogeneous material for RoHS vs. article for REACH), this might lead to differing calculation of concentrations of a substance of concern. For borderline cases this could mean differing obligations.
To get an answer to many more questions concerning SCIP database watch the video, download the white paper, follow our blog, and get in touch with our experts via email.
ECHA drops one mandatory field for SCIP database reporting
During the last SCIP database workshop on March 17th, 2020, ECHA indicated a change to the mandatory fields for SCIP reporting. Upon iPoint’s inquiry, an ECHA representative confirmed that the field “Candidate List Version” will no longer be mandatory upon the go live of the SCIP database in October 2020. With this decision, ECHA has taken stakeholder concerns into account, since the official Candidate List of Substances also does not have a version itself.
During ECHA’s IT user group meeting on March 20th, 2020, more information was revealed. Not only will the “Candidate List Version” be dropped as a mandatory field, there will also be changes to the picklist values of the “Production in EU” category. From October 2020, options will be:
- EU produced
- EU imported
- Both EU produced and imported
- No data
This will make opting for a default value for the better part of a company’s SCIP-reportable products far easier.
Furthermore, distributors will have the option to reference dossiers already submitted. This means that they will not have to submit dossiers themselves. In addition, it will be possible to submit one dossier for articles of the same type with slightly differing characteristics, e.g. O-rings of different colour or dimensions, which could significantly reduce the number of dossiers for duty holders.
Despite the current situation concerning COVID-19, ECHA continues its work but is of course closely monitoring the situation. As soon as we get any news, iPoint will continue to keep you updated via this blog.
Building on iPoint’s long-standing experience in dealing with product variants and inter-connections, these modifications will be included in iPoint’s system-to-system SCIP solution.
Sneak Peek at iPoint’s SCIP Connector
See a live demo of the iPoint Compliance SCIP Connector that automates the creation of SCIP dossiers and the exchange of data with ECHA`s new SCIP database.
Sneak Peek at iPoint’s SCIP Connector
• Management of your company’s one or more ECHA UUIDs required for SCIP submission
• Extensive options of default settings allowing easy initial SCIP reporting on the basis of existing data
• Management of product details and setting of SCIP relevance
• Dossier Creation, Validation and Upload
SCIP FAQ: The Echa SCIP Database – Get the answers on the TOP 40 frequently asked questions
Our SCIP FAQ document provides a summary of frequently asked questions concerning the SCIP database that iPoint has come across in our discussions with stakeholders. The following topics are covered:
✔ Reporting requirements
✔ RoHS and SCIP
✔ iPoint’s SCIP solution
✔ Automated submission
✔ (Additional) Data requirements for SCIP submission
✔ BOM level reporting
✔ Validation checks
✔ iPoint’s IMDS connection
SCIP database to be launched in late October – no indication that deadline in January 2021 will be postponed
The European Chemical Agency ECHA informed that during the last week of October, the SCIP database will be formally open for submitting notifications to comply with the legal obligation – months in advance of the entry into application date. The obligation to submit data to SCIP starts to apply from 5 January 2021, as outlined in the Waste Framework Directive. ECHA has no indications that the deadline would be postponed and encourages companies to continue their preparations.
The iPoint Compliance SCIP Database Connector has been already successfully tested with the preliminary version of ECHA’s SCIP Database and is ready to automate the creation of SCIP dossiers and the exchange of data as soon as the database is officially launched.
SCIP reporting using IMDS system vs. iPoint SCIP connector
We are all aware that SCIP reporting requires a considerable effort for almost all affected companies. Thus, every form of facilitation is helpful, such as the IMDS system presented at the IMDS & PRODUCT CHEMICAL COMPLIANCE CONFERENCE 2020, hosted by AIAG on October 13th and 14th. Still there are time consuming manual steps left, that can be eased with iPoint’s SCIP connector.
Implementation of SCIP relevant properties in IMDS release 13
With IMDS Release 13 (available in March 2021) it will be possible to include SCIP-related data to a dataset, in particular a declaration of Production in European Union, TARIC code information and Safe Use Instructions. Since SCIP database requires the description of a material (or mixture) category at the so-called concern element level, it will be possible to add one or more material categories. This selection is aided by a mapping of current material classifications to the ECHA category options.
These steps, as well as the upload to SCIP database need to be done individually for each dataset in IMDS.
SCIP reporting efforts using IMDS system
However, SCIP reporting within the IMDS system requires two significant steps:
- Determination of SCIP reporting necessity (SVHC analysis)
- Data collection, entry, and submission of dossiers for these datasheets.
Assuming an effort of 10 minutes for the SVHC analysis per datasheet and 30 minutes to do the submission for a complex object, SCIP reporting will still take around 750 hours to complete in an average case! (Assumption: 20.000 MDS, 50% of these put on EU market, 15% have at least one SVHC > 0.1% w/w).
How to ease the burden with iPoint
One of the biggest challenges in SCIP reporting is the handling of a large number of products to be reported. iPoint’s SCIP connector has been developed to enable this bulk processing of datasets. Based on our established functionalities SVHC analysis can be done automatically across all products as well as
- Roll-up of results for an easy overview
- Bulk definition of products put on EU market (and therefore SCIP relevance)
- Bulk maintenance of BOMs and article categories and other SCIP mandatory properties
Data collection from suppliers is necessary to provide all mandatory data of a SCIP dossier – and to meet the deadline of January 5th, 2021. This will have to happen before the options are available in IMDS. For this reason, iPoint allows to leverage default settings and ECHA waiver options as well as bulk import of data in order to successfully complete the initial SCIP submissions on time. Once the supplier data is available via IMDS, it can be used to easily update dossiers from within iPoint’s SCIP solution. Last but not least, iPoint supports the bulk submission of datasets and simplified notification option, making reporting fast and straightforward for a large number of products and legal entities.
This combination of automation and bulk handling options will reduce efforts to under one hour for the example above.
New IUCLID version by ECHA
ECHA will release the new version of IUCLID (https://iuclid6.echa.europa.eu/) on October 28th. With that the release of version 1.0 of the SCIP database is also expected, for companies to fulfil their reporting obligation under the Waste Framework Directive.
Preparations for January 2021 in full swing
The obligation to transmit data will be effective as of January 5, 2021. With only ten weeks left, a lot of companies are already well on the way of dossier preparations.
Over a dozen international companies which are key players in automotive, electronics, and MedTech industries are already using iPoint’s solution to prepare data and submit dossiers into the ECHA test environment and are up and ready for dossier submission come the release of ECHA’s SCIP version 1.0.
Alternative: list customers by name (for those for which we are allowed to do so) but keep the text flexible: some customers are already testing, some are still waiting for the installation
How iPoint helps you
iPoint’s SCIP Connector offers the following advantages:
- Simple impact analysis and data overview
- Easy completion of mandatory dossier fields
- Simple creation of dossiers based on existing data
- Transmission of large amounts of data through the system-to-system interface
On top of that, the next release will feature even more options:
- Submission history overview
- Definition of reporting hierarchy
- Easy use of the Simplified Notification Option for legal entities within a company to bulk submit SSN dossiers
- Granular user management for workflows within large companies
Get started now
With not much time left, we recommend getting started now. Prepare and submit your data step by step, rather than waiting until January 5, 2021, especially if there are many dossiers to be submitted. In this case a system-to-system interface such as iPoint offers is highly recommended.
Since ECHA are expecting a large amount of data and a large number of requests for the necessary S2S keys, iPoint therefore recommends starting now to obtain these S2S keys in order to enable access to the database via a system-to-system interface and thus to transfer data successfully.
SCIP Database Connector Enterprise & Professional released
Hear about the latest updates on ECHA SCIP database and see a live demo of the officially released iPoint’s SCIP Database Connector. Our software solution is recognised by ECHA and already evaluated by many companies worldwide to enable them to meet their compliance reporting obligations by the by the deadline of January 5, 2021.
Learn about what an automated response could look like to make SCIP submissions and get acquainted with the features in the iPoint software solution for both enterprise and professional level.
What’s in it for you
Learn about the latest updates on ECHA SCIP database
Get insights about the challenges of manual efforts associated with making SCIP submissions
See a demo of SCIP Database Connector Enterprise & Professional
Download our free White Paper – SCIP database insights
Get an in-depth insight into SCIP database – What is required, and how you can get started.