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The SCIP FAQ
As commissioned by the revision of the EU Waste Framework Directive (EU)2018/851, the European Chemicals Agency (ECHA) has set up a database to collect information on products brought onto the EU market containing an article with an SVHC content of above 0.1% w/w now called SCIP (Substances of Concern In articles as such or in complex objects (Products)).
Duty holders must report their data to SCIP database since January 5th, 2021. Meeting the SCIP reporting requirements often is a laborious task for the duty holder, given the extent of information necessary to even just fill the mandatory data fields. This FAQ provides a summary of a wide range of frequently asked questions concerning the SCIP database that we have come across in our discussions with stakeholders.
Duty Holder Responsibility
Who needs to prepare a SCIP dossier?
SCIP addresses companies that are located within the EU. The scope of SCIP is all articles that are placed on the EU market and thus finally end up as waste within the EU. The following suppliers of articles need to provide information to ECHA:
- EU producers and assemblers,
- EU importers,
- EU distributors of articles and other actors who place articles on the EU market.
Retailers and other supply chain actors supplying articles directly to consumers are not covered by the obligation to provide information to ECHA. According to Article 3 (33) of the REACH Regulation, the supplier of an article means ''any producer or importer of an article, distributor or other actor in the supply chain placing an article on the market". The obligation to provide information to ECHA starts with the first EU supplier (whether a producer or an importer), because they have or should have the best knowledge of the article. Guiding questions to identify if you are a duty holder:
If you can answer “Yes” to one or more of the following questions, then you are a duty holder:
- Do you import articles into the EU and sell it to participants of the EU market?
- Do you produce articles or assemble articles within the EU and sell it to participants of the EU market?
- Do you distribute articles on the EU market?
- Do you modify articles for sales on the EU market?
For more information, please see this ECHA page to understand requirements: echa.europa.eu/scip-suppliers-of-articles
Is a non-EU company required to report to the SCIP database?
A non-EU company cannot submit to the SCIP database. There is the option of submitting on behalf of an EU company (e.g., a subsidiary), but in this case the EU company must be used to create your logins and IUCLID account. iPoint SCIP can handle diverse organizational set-ups to assist with fulfilling complex supply-chain and reporting obligations.
If I am a non-EU supplier selling products containing SVHC to EU customers, what information do I
need to give my customers?
This depends on both your B2B contracts as well as on your due diligence processes. We suggest supplying information to your customer:
- on the SVHC contained,
- SVHC content (within the ranges required by SCIP database),
- material or mixture category of the SVHC containing material or mixture, information on the article (e.g., component name),
- information on the complex object (product number, name).
If your customer is using iPoint Compliance, you can easily accomplish this through our supply chain communication modules.
What if I am a supplier of articles from outside the EU?
The responsibility for fulfilling the obligation of providing information to ECHA lies with the EU importer. Companies that operate entirely outside of the EU are not subject to this obligation and are not allowed to submit SCIP notifications.
Importers of articles in the EU however need to turn to their non-EU suppliers of articles and request information to be able to fulfil their regulatory obligations, such as the obligation to provide information to the SCIP database. As a non-EU supplier of articles, you should support your EU customers by providing the necessary information about the presence of Candidate List substances in your supplied articles.
An EU importer may set up contractual agreements with their non-EU suppliers of articles to act on their behalf (as a “foreign user”), regarding the submission of data to the SCIP database. However, the responsibility of the SCIP notification and its content still lies with the EU importer of articles. Please be aware that the third-party users (“foreign user”) will see the same information as all other users in the ECHA IT tools.
As a manufacturer with headquarters outside EU and subsidiaries in the EU, who wish to report with the ECHA’s SCIP-trial database, do I need to do this via one of our EU subsidiaries?
Yes. Reporting to SCIP database (and this includes the trial environment) is only possible for EU based companies. Therefore, you are required to work with the access data of an EU based subsidiary. Reporting with a non-EU account will lead to a validation failure. In any case, we recommend that you reach an internal company agreement on how to handle SCIP reporting requirements. Here's how you can create an ECHA account: echa.europa.eu/documents/10162/13567/howto_account_manual_industry_en.pdf/9e84c2fb-c876-30a7-7eb9-fde40e968ef5 It is every duty holder’s responsibility to get an IUCLID ID from ECHA for SCIP submission.
I assemble a complex article with a single component with an SVHC above 0.1% w/w in the article. Who must prepare the dossier? My company, or the creator of the single component, or everybody in the supply chain?
If your company is in the European Union and you are bringing the product to the EU market, you must report the complex object to the SCIP database. It is however your supplier’s duty to report the SCIP dossier for the supplied article (unless you also act as the importer of said article).
With regards to this sub-article, you have the option to either include the full information on the article containing the SVHC >0.1% w/w or reference it by utilizing the SCIP number of the dossier created by the supplier. This however requires that you obtain this SCIP number from your supplier.
NOTE: You are not able to search for (and reference) the article solely within the SCIP database at time of writing. Data dissemination is planned by ECHA for September 2021.
Are the reporting requirements applicable to all products in the market or only to new ones?
The requirements are applicable to all products brought onto the EU market after January 5th, 2021. The obligation applies to all articles as such and in complex objects containing an SVHC >0.1% w/w that are placed on the EU market. The goal of the SCIP database is to collect data on all products placed on the EU market and to obtain information about what will eventually end up as waste. This includes spare parts, components, and packaging.
My product has industrial/commercial uses only, not consumer. Do I still need to provide information to SCIP?
Are there any items/products that are exempt from registration?
How can I identify the products that need to be reported?
If the following two criteria apply to your product, you are obliged to report to SCIP:
- The product is brought onto the EU market. You can typically obtain this information from your sales organization.
- One or more articles in the product (based on O5A principle - once an article, always an article) contains an SVHC >0.1% w/w
It appears we don’t need an entry for each product, but rather for each product variation. How can we handle SCIP reporting if we must submit dossiers for a very large number of items? Do you have any strategies for this?
There are various approaches that you can take:
- iPoint SCIP offers 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.
- We recommend starting with a sample or representative version of all products before looking at variants.
Do I have to declare each individual part, or can I declare generic parts as well?
It is up to the duty holder to decide the best approach to submit a SCIP notification which is compliant with the obligation set out in the Waste Framework Directive and to support their customers and waste operators. ECHA’s recommendation for articles meeting the criteria mentioned below is to submit them all in the same SCIP notification, provided that the right elements for the identification of each identical article (e.g., names and alphanumeric identifiers) are included in the notification. The criteria are:
- The articles have the same function or use (e.g., same name and article category).
- The articles contain the same Candidate List substance(s).
- The material that the articles are made of is the same.
- The safe use instructions are the same, which is a logical consequence of the previous two criteria.
Which information needs to be reported to ECHA?
All reporting requirements can be found in ECHA’s publication “Requirements for SCIP notifications” published in October 2020. You can find this document and other helpful documents at SCIP support - ECHA (europa.eu). SCIP reporting requires more data than just the name of the SVHC present and related information on safe use, as is the case for REACH article 33(1).
How does the waste operator know if e.g., multiple O-Rings are submitted in SCIP, which one it is, if they look the same, but contain different SVHCs?
This can be difficult but making sure the O-rings are easily identified will help, for example having the part number printed on them or color-coding them. ECHA made the first data publicly available by the end of September 2021. Article details as well as information on the concerned element are accessible to waste operators.
How many types of SCIP dossier are there?
There are three types of dossiers as follows:
- Full: contains full details of the SVHC, safe use instructions, etc.
- Simplified SCIP Notification (SSN): used by other legal entities after the Full submission is complete.
- Referenced: used when an article in your product has its own dossier (either from your suppliers or from your own internal team).
What is a Simplified SCIP Notification (SSN)?
Simplified SCIP Notifications should be used if the same article is brought to the EU market by multiple legal entities (e.g., company subsidiaries or distributors). Once a full dossier has been submitted for the first legal entity, then ECHA strongly recommends using the Simplified SCIP Notification option to submit the SCIP dossiers for this product for all remaining entities.
When a new substance is added to the Candidate List, until when do I have to update this information into the SCIP database?
There is no timeframe defined in the Waste Framework Directive, but this EU directive is transposed into member state legislation, where further details and enforcement actions can be specified.
Previously, a widespread 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 and does not necessarily have to be the case for SCIP reporting requirements. iPoint SCIP automates checking your products against the latest SVHC list, thus supporting a rapid update of SCIP dossiers in case of relevant Candidate List changes.
Nevertheless, the REACH reporting obligations according to REACH Art. 33 needs to be fulfilled. This requires informing the B2B partner as soon as knowledge about any SVHC content >0.1% w/w is available. For B2C communication, companies need to provide a reply within 45 days after a consumer inquiry.
Some ECHA substances are groups, e.g., SCCP (Short Chain Chlorinated Paraffins). Does iPoint refer to the substances as listed in the Candidate List or add extra CAS numbers?
SCIP dossiers can only refer to the substances listed in the Candidate List, more specifically to the exhaustive list provided by ECHA. You can find the list here: echa.europa.eu/candidate-list-package.
Do I have to report any other substances besides those covered in the Candidate List Package?
RoHS and SCIP
Is SCIP related to RoHS and WEEE regulations?
No. The SCIP database is based on the Waste Framework Directive and on REACH Article 33(1) reporting obligations. 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.
Do I have to report to SCIP even if I use a RoHS exemption?
Yes, ROHS exemption does not apply to REACH SVHC. It is very likely that the SVHC content also exceeds the 0.1% w/w threshold for SCIP reporting related to the O5A principle (once an article, always an article). In other words: Using a RoHS exemption does not render REACH reporting unnecessary.
However, knowing that a RoHS exemption for lead is used means that you will probably need to report according to REACH Article 33(1) and to SCIP.
NOTE: The reference point for calculation is different for RoHS (homogeneous material) and REACH (article). This means that in borderline cases, a product that requires a RoHS exemption might not require SCIP reporting..
iPoint's SCIP solution
Which tasks are performed by the iPoint SCIP Database Connector?
The iPoint SCIP Database Connector is a web-based application. It comprises the following key features:
- Extraction of SCIP relevant data from your iPoint source system OR
- Import of SCIP relevant data for a stand-alone solution (SCIP Essential)
- Setting of global defaults for several standard mandatory fields for rapid dossier creation
- Management of multiple ECHA UUID(s)
- Full dossier creation
- Simplified SCIP Notification (SSN)
- Management of ECHA SCIP dossier IDs and their history
Which key items do I have to check to ensure the correct workflow for SCIP reporting in the iPoint SCIP Database Connector?
As a minimum you need details of SVHC contents at article level for all products sold or supplied in the EU.
NOTE: Mixture/materials can be considered as an article as well, and as such it needs the same set of information as every higher-level article.
To create a dossier, you also need all the other mandatory data points required by ECHA. However, you can enter these directly in the iPoint SCIP Database Connector or supply them using default values for your organization.
Does the iPoint SCIP Database Connector allow bulk submission of data?
Does the iPoint SCIP Database Connector support creation of Simplified SCIP Notifications (SSN) for multiple legal entities which all sell the same product in the EU?
How does the iPoint SCIP Database Connector submit data to ECHA?
iPoint's SCIP solution
Is the iPoint SCIP Database Connector a standalone app or a module within iPoint Compliance?
Is it possible to use the iPoint SCIP Database Connector independently of iPoint Compliance or with other IT Compliance solutions?
If you already have a compliance system from iPoint, the iPoint SCIP Database Connector comes as an add-on. If you have a non-iPoint compliance system, we offer a stand-alone version – SCIP Essential – that enables you to maintain SCIP-relevant information and benefit from:
- bulk-uploads to the ECHA database,
- preference settings for default values,
- task management features,
- history of dossiers.
What does the interface to my ERP system look like?
Is the iPoint SCIP Database Connector a web application?
IPC1752B and IEC 62474 both have additional fields for SCIP reporting. Will iPoint be supporting these?
Can the iPoint SCIP Database Connector submit SCIP notifications and provide the SCIP dossier number and SCIP number?
Can I see the dossier status in the iPoint SCIP Database Connector after submission?
iPoint's SCIP solution
How and how often are updates reported to the SCIP database? Automatically, or at the push of a button?
The goal is to report updates to the SCIP database as soon as possible when a previously submitted product has been modified. A modification is represented by one or more of the following options:
- A new SHVC in the product – either because the Candidate List changed, the product composition changed, or a supplier corrected a substance report.
- A previously reported SVHC is no longer present in the product.
- A different article (compared to the previous report) within the complex object contains an SVHC.
- A change in the dataset (for example updated TARIC code, updated material, or mixture category).You must approve the data and request the dossier submission as with new dossiers.
After a dossier update, the SCIP number remains the same, but with the latest details, correct?
iPoint's SCIP solution
(Additional) Data Requirements for SCIP Submission
Are there standard Safe Use Instructions (SUI)?
No. ECHA and iPoint do not issue or use a list of standard safe use instructions. However. you can use the Standard ECHA option to say that only the SVHC needs to be identified. The iPoint SCIP Database Connector supports this by allowing you to set an item or default to “No Need to Provide”, OR choose one or more of the following:
- Set Default Safe Instructions at both product and purchase part level.
- Enter Text in iPoint Compliance (if used) or directly in iPoint SCIP.
- Provide SUI by SVHC from iPoint Compliance (Some configuration is required).
Does the iPoint SCIP Database Connector translate actual Tariff (TARIC) codes into the IUCLID standard?
Can I select the TARIC code from a list?
Can I enter data into the iPoint SCIP Database Connector?
iPoint's SCIP solution
BOM Level Reporting
Up to which depth do I have to report a complex object?
ECHA’s recommendation is to construct the dossier for a complex object based on practical considerations. It should include the lowest number of layers need to identify the location of the SVHC: ECHA’s recommendation is to typically limit the depth to three to five, maximum seven levels for complex objects. Your responsibility as duty holder is to avoid disclosing confidential information (e.g., detailed product composition or trade volumes). iPoint SCIP supports you to define the number of layers to be reported.
Can the iPoint SCIP Database Connector support merchandising and franchised items?
As a legal entity in the EU, you must report all the products you bring into the EU market. This includes items made on your behalf for merchandising purposes. Details of these are not always held in your main PLM/ERP system.
We suggest adding these to the PLM/ERP system and collecting the relevant SVHC and article. Other iPoint products can be used to assist in the data collection. Please contact our sales representatives for more information.
Can the iPoint SCIP Database Connector accommodate incomplete data?
Yes. If the minimum data is available iPoint can create dossiers that combine different levels of detail on each part. The iPoint SCIP Database Connector can be configured to just display and submit the minimum data or a mixture of data levels depending on the level of data collected from your suppliers. Please contact our sales representatives for more information.
When I report to SCIP on complex purchased parts such as circuit boards, do I need to insist on full declarations or is substance level enough?
Most customers utilize what their suppliers can provide. This is at a variety of levels and the details will improve over time.
iPoint recommends that you look at ways of improving the quality of data over time. iPoint can assist with this effort. Please contact our sales representatives for more information.
iPoint's SCIP solution
Does the iPoint SCIP Database Connector support validation checks of SCIP dossiers?
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 iPoint Compliance Professional, 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.
What is the process in the iPoint SCIP Database Connector if the SCIP validation process does not pass?
If a dossier validation fails the validation checks, then the reason is displayed on the ECHA portal. A validation check failure is normally due to missing required data but can also occur because your dossier is too large. Check the reason of the validation failure and fix the data before submitting it again.
You should complete the missing data before re-submitting. This may mean changing the default data. If you cannot clear the issues, please contact our support team.
Connection to IMDS
Can iPoint’s solution download SCIP information from IMDS?
Is all the data available in IMDS?
iPoint Compliance already integrates with IMDS. iPoint Compliance transfers the IMDS SVHC and structure data to the iPoint SCIP Database Connector as well as your product details and BOM structure. The ECHA SCIP material classification mapping is done based on the VDA classification in the IMDS datasheet and following the mapping agreed upon between ACEA and ECHA.
The Echa SCIP Database
Our new updated SCIP FAQ 2021 is a summary of a wide range of frequently asked questions concerning the SCIP database that we have come across in our discussions with stakeholders in the last months.