SCIP FAQ

We have received a lot of questions on the upcoming SCIP Database. Here are the answers on the TOP 40 frequently asked questions.

The SCIP FAQ

 

In the revision of the EU Waste Framework Directive (EU)2018/851), the European Chemicals Agency ECHA was tasked to set up a database to collect information on products put on the EU market containing an article with an SVHC content of above 0.1% w/w. The reporting requirements, which come into effect on January 5, 2021, are a laborious task for the duty holder, which is complicated by unclear requirements and ongoing modifications ofthe requirement details. This FAQ provides a summary of frequently asked questions concerning the SCIP database that iPoint has come across in our discussions with stakeholders.

 

For ease of handling, they have been arranged to cover the following topics:

  • 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

Reporting requirements

Is a non-EU company required to have IUCLID Registration?

 

A non-EU company will not be able to submit to the SCIP database, therefore: no. There will be an option of submitting on behalf of an EU company (e.g. a subsidiary), but in this case the IUCLID ID for the EU company has to be used. 

Are the SCIP reporting requirements applicable to all products in the market or only to new ones?

 

The SCIP requirements are applicable to all products brought onto the EU market.

Our product has industrial use only, not consumer. Do we still need to provide information to SCIP?

 

 Yes, all products brought onto the EU market need to be reported to ECHA's SCIP Database.

It appears we will NOT need an entry for each product, but rather for each product variation. For some companies this could still be a very large exercise. Do you have any strategies for this?

 

There are various approaches that could be taken:

  • iPoint’s SCIP solution will give the option of using default values for various mandatory fields to simplify initial reporting while maintaining the possibility of adjusting for individual product specifics.

  • We recommend targeting the key products (e.g. selected by sales volume) first.Based on ECHA's information in the IT user group meeting on March 20, 2020, it shall be possible from October 2020 to submit one dossier for articles of the same type (i.e. containing the identical SVHC in the identical material). This approach will be supported by our solution.

I assemble a complex article with a single component with SVHC > 0,1 %. Who has to prepare the SCIP dossier? My company or the creator of the single component or everybody in the supply chain?

 

If your company is located in Europe and you are bringing the product to the EU market, you have to report the complex object to the SCIP database. At the current stage including the information on the article containing the SVHC > 0.1%. ECHA is planning to include the option of referencing until October 2020. From then, you will need to report the complex object but could reference the article, provided your supplier has submitted a dossier on the article and provided the information for referencing to you. Please note that you will not be able to search for (and reference) the article solely within the SCIP database.

When a new substance is added to the Candidate List, how much time are companies given to update this information into the SCIP database?

 

There is no timeframe defined in the Waste Framework Directive, but this EU directive needs to be transposed into member state legislation by July 5th, 2020, where enforcement actions will be specified. A common practice by enforcement bodies has been to consider a timeframe of one year acceptable, but this is of course dependent on the national enforcement authority.

For a specific SVHC, e.g. SCCP do you refer to the substances as listed in the candidate list or any C10 to 13 chloro species?

 

You can only refer to the substances listed in the Candidate List, more specifically to the exhaustive list provided by ECHA.

To which level of detail does TARIC need to be entered? Are 10 digits required or can it be less? This could be important for confidentiality.

 

In ECHA‘s IT user group meeting on March 20, 2020, ECHA announced plans to extend all TARIC codes to 10-digit by adding "0".

If I am a non-EU supplier selling products containing SVHC to EU customers, what information do I need to collect for SCIP?

 

This of course depends on both your B2B contracts as well as your due diligence processes. We suggest supplying information to your customer on the SVHC contained, its content (within the ranges required by SCIP database), material or mixture category of the SVHC containing material or mixture, information on the article, and information on the complex object. If your customer is using iPoint Compliance, you can easily accomplish this through our supply chain communication modules.

How will the waste operator know if e.g. multiple O-Rings are submitted in SCIP, which one it is, if it looks more or less the same, but contains different SVHCs?

 

Since ECHA has not yet published how the information submitted to the SCIP database will be made available to waste operators, this question cannot be answered at this point in time.

RoHS and SCIP

How is SCIP related to RoHS and WEEE regulations?

 

The SCIP database is based on the Waste Framework Directive and linked to REACH Article 33(1) reporting obligations. Thus, there is no direct relation to RoHS and WEEE. These are different legal acts and if you are a duty holder you need to comply with all of them. Additionally, considering that some RoHS-regulated substances such as lead or DEHP are also part of the SVHC list might help you identify the compliance status and reporting obligations

iPoint’s SCIP solution

Why should I use iPoint’s solution for SCIP reporting?

 

iPoint’s SCIP solution has been developed to minimize the effort of SCIP reporting. There are several benefits of using our web-based system-to-system solution:

  • First and foremost, the bulk upload of data to SCIP database, allowing the easy and fast submission of a large number of SCIP dossiers.

  • Data required for SCIP reporting, that is required in addition to data already available in iPoint Compliance can easily be added.

  • Thus, mandatory fields can be filled by available data or pre-set default values.

  • Another benefit is the applicability not only to new products but to legacy data also, especially in conjunction with the option to set default values (that might differ from company to company).

  • This is further extended by the option to adjust these defaults for individual selections, where a bulk change is also possible.

  • In addition, all non-IMDS cases are also covered by iPoint. This is required even in the automotive industry, e.g. for merchandising products.

  • For OEM companies, the iPoint SCIP solution offers the possibility to maintain their vehicle BOMs as well as aggregate BOMs of several vehicles and thus notify a vehicle series.

  • iPoint’s SCIP solution will of course leverage the well-established ways of supplier communication by iPoint’s solution, thus supporting the refinement of data and consequently an iterative improvement in SCIP dossier data and evolution of SCIP reporting.

What is iPoint’s proposed workflow for using their solution?

 

iPoint's SCIP solution will be a web-based application and comprise the following features:

  • Extraction of relevant data from iPoint Compliance

  • Additional adjustment of "SCIP relevance"

  • Overview via a Dashboard feature: current activities, historical registrations

  • Setting of global default values for several mandatory fields

  • Adjustment of default settings for individual datasets

  • Management of IUCLID registration IDs

  • Handling of single as well as bulk selection of products

  • Search functionalities

  • Bulk upload of data

  • Management of ECHA SCIP dossier IDs

We do require bulk submission of data. Will iPoint’s solution enable this?

 

iPoint's solution will create a dossier in the i6z format and automate SCIP database upload via the system-to-system interface. We will include bulk upload capabilities.

What are the IT requirements for iPoint’s SCIP solution?

 

The SCIP module will be a web-based solution, for a client, a web browser like Chrome or Edge will work. For a server, the SCIP module can be installed on the same server as iPoint Compliance. Additional technical details regarding memory etc. are still being defined and will be shared when ready.

What are the pre-requirements for iPoint’s SCIP solution?

 

Please check the How-To Guide and the Checklist from iPoint for details.

Will iPoint’s SCIP solution be available in October 2020?

 

The Beta-Version for testing in our customer community will be available in Q3/2020. We will align our final release with ECHA's release dates as closely as possible.

Will a demo of iPoint’s SCIP solution be available?

 

Yes, a demo of the SCIP solution will be available when the solution is ready. We are currently targeting our first internal release to be available in early July and Beta-Release for customer testing in Q3/20. A demo will be prepared in parallel.

What is the cost for iPoint’s SCIP solution?

 

Please get in touch with our sales representatives, who are happy to help. 

Will the iPoint solution include the optional fields or will it be limited to the mandatory fields?

 

Mandatory fields will be covered, optional ones are not included in the first iPoint SCIP solution. We will provide bulk edit capability to edit multiple records at once.

Is there any manual input needed into SCIP, before being able to use the iPoint SCIP connector?

 

No, there is no manual input to SCIP database required. All the data handling as well as the automatic bulk upload can be done via the iPoint SCIP solution. iPoint is striving to automate as much as possible and considers the setting of default values to reduce manual effort.

Do I need a IUCLID registration even with the SCIP Connector solution?

 

Yes, submission requires the duty holder's IUCLID ID.

 

The iPoint SCIP solution allows to set and manage multiple IUCLID registration IDs and select the appropriate ID or IDs for reporting, e.g. also allowing for on-behalf reporting of a mother company for subsidiaries or vice versa.

As a user of iPoint Compliance, do I have to buy VP and/or PI module to work with iPoint’s SCIP solution?

 

Yes, this will allow us to focus our solutions and also deprecate older modules. Please contact our Product Management for the specifics of any exceptions.

I already have a compliance system. Do I need to replace it in order to use your SCIP connector?

 

If you already have a compliance system from iPoint, the SCIP module is an add-on to this. If you have a non-iPoint compliance system, the first iPoint SCIP solution will not work with this. However, due to the fact that this question has come up a few times we are re-evaluating this decision.

Will iPoint’s SCIP solution be able to submit SCIP notification dossier and provide with SCIP reference number?

 

Yes.

Will iPoint’s SCIP solution be able to provide the final report with reference number?

 

Yes.

Automated submission

Will the creation of a SCIP notification dossier, submission, and validation be fully automated in iPoint’s SCIP solution? If not,which data will the user have to set manually?

 

The process will be automated as far as possible and based on the well-established processes of the iPoint Compliance software.

 

All data required for SCIP reporting will be included in the iPoint Compliance solution, as data field. For those sets of data not yet maintained in iPoint Compliance by the user company, e.g. TARIC code or specific safe use information, some manual effort might be required. The iPoint solution will also allow the setting of default values for a number of mandatory fields to further reduce effort.

 

Dossier creation, validation, and submission will be automated

(Additional) Data requirements for SCIP submission

How will the iPoint solution deal with the additional data that is required for SCIP reporting?

 

Additional data needed for products can be imported in iPoint Compliance.

 

Additional data fields required for purchased parts will be included in our solution in SuHu/MC, as well as in the IMDS environment. The first iPoint SCIP solution is not focused on explicitly collecting supplier data but will leverage defaults.

 

Still already today iPoint Compliance is able to request REACH-relevant information about purchased products from the supply chain. This feature will be amended to cover SCIP specific information such as the Tariff Code, Safe Use Information and EU Production.

 

In addition,  there will be a chance to manually maintain or set default values in the SCIP module, for cases where missing data still is an issue.

Can additional information be include into the process for SCIP Notification?

As for the additional information that we need to include into the process for SCIP Notification like e.g. Taric Codes, Material Classifications etc. – is it planned that it can be included for supplier communication already (for material I think this would make sense) in order to have the data included into the iPoint Compliance solution?

 

Yes, this will be included in iPoint’s solution.

 

Can supplier SDSs, giving information on SVHC content, be included in Point’s SCIP workflow?

 

iPoint’s Compliance solution allows the attachment of documents, e.g. also SDS. This information can be utilized to enrich product data by SVHC information, which in turn then will be the basis for SCIP reporting.

Candidate List date: Will the iPoint solution translate the candidate list date into the IUCLID format (e.g. 2020/1, 2020/2, 2020/3,...) or do we need to maintain this data somewhere?

 

The Candidate List version field will be removed in the October 2020 version of the SCIP database. Information on the Candidate List date used for compliance checks is available in iPoint Compliance.

 

The SCIP database is so far not able to add a hazardous substance to a complex article (e.g., potting of electronics). How do you manage this?

 

This indeed is still an open question which we address to ECHA via the IT user group. However, it is possible to report an article containing an SVHC (and thus a concern element). This simple reporting could be a solution for the initial SCIP reporting in this case.

Is there an Article Number in iPoint’s SCIP solution?

 

The iPoint solution will handle multiple product identifiers, and also link the dossier's SCIP ID to the datasheet of the iPoint software.

 

Tariff code: Will the iPoint solution translate actual Tariff codes into the IUCLID standard or does the system need to be populated by these numbers?

 

The Tariff code will have to be provided to iPoint's system, either via selection of a default (where possible), data transfer from ERP/PDM system or import / manual entry. The category description related to the Tariff code will be available in the iPoint SCIP solution and mapped to the article categories in the SCIP data base.

How will iPoint’s SCIP solution link articles to the Taric code?

 

There will be three possible approaches (and combinations of these):

  • Setting of a default value

  • Import from the ERP/PDM system

  • Provided by you via an uploadable file

 

BOM level reporting

How is a flat BOM versus a structured BOM handled for privacy?

 

According to ECHA, connections between supply chain actors will be kept confidential in case of submission of a structured BOM information. However, responsibility for the data submitted lies with the duty holder. Therefore, we strongly recommend evaluating the sub-component information submitted and make sure that the data put into the mandatory fields gives no indication on the supplier.

 

From a technical perspective, our software is capable to provide both information on flat and on structured BOMs. Prerequisite is the availability of the data.

Validation checks

We assume that iPoint‘sSCIP solution will support to create a SCIP notification dossier, including submission to SCIP via validation check. Is this correct?

 

Yes.

What is the process in iPoint’s SCIP solution if the SCIP validation process does not pass?

 

Datasets will be checked against ECHA's validation rules before creation of the submission file to allow for correction before upload.

iPoint’s SCIP IMDS connection

Will iPoint’s solution be able to download information from IMDS (article with SVHC >0.1 %, article name, primary article identifier, candidate list substance, CAS No, substance range, substance path, number of units in complex object)?

 

The SCIP module is an add-on to the iPoint Compliance solution. iPoint Compliance solution already integrates with IMDS, as such SCIP module will also have access to SCIP relevant information coming from IMDS.

 

In cases where a transfer of data or an automated mapping is not possible, iPoint is including the option of setting default values.

How will other SCIP mandatory data (TARIC code, material classification, safety use instruction) be linked in iPoint’s SCIP solution in order to create a SCIP notification dossier? Will you need any additional data which are not available in IMDS?

 

At current stage, it is not yet defined which SCIP relevant information will be provided by IMDS in future. But since iPoint Compliance solution already integrates with IMDS, iPoint’s SCIP module will also have access to SCIP relevant information coming from IMDS. 

 

A material classification mapping is being done by iPoint experts. This also includes the mapping of VDA material classifications to SCIP material and mixture categories. This means that product information that already have a material classification will be reusable, without any need of manual data maintenance.

 

In cases where a transfer of data or an automated mapping is not possible, iPoint is including the option of setting default values.

 

In addition, the iPoint SCIP solution will offer a possibility to import SCIP relevant data (e.g. Tariff code) or maintain the data manually for a SCIP dossier.

How will iPoint’s SCIP solution link VDA material classification used in IMDS to SCIP material classification?

 

Material classification mapping is done by iPoint experts. This also includes the mapping of VDA material classifications to SCIP material and mixture categories. This means that product information that already have a material classification will be reusable, without any need of manual data maintenance.

Get in touch

Europe and Asia Pacific

Hans-Gerhard Lang

> Email

Phone +49 7121 14489 777

North America

Marc Church

> Email

Phone +1 248 282 4085

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