Frequently Asked Questions about SCIP

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

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.

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.

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.

No, there are no standard exemptions. Member states may allow for exemptions in specific cases of national interest (these are usually defense and national security).

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.

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).

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).

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.

No. ECHA request that you only use the ones on their list.

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.

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

Yes. The iPoint SCIP Database Connector allows you to request that dossiers are created for multiple products at the same time.

The iPoint SCIP Database Connector uses the ECHA system-to-system (S2S) interface to submit dossiers and request status updates. You need to have access to the ECHA database and set up your legal entities and ECHA users before using the iPoint SCIP Database Connector.

The iPoint SCIP Database Connector is a web-based application and extracts relevant data from iPoint Compliance. It is part of the iPoint Suite. Other variations such as a stand-alone version (SCIP Essential) are available, for more details please get in touch with our sales representative.

The iPoint SCIP Database Connector does not interface with any ERP system directly. This is typically done by other iPoint products. SCIP Essential does allow you to supply SVHC and Article data via a standard interface, for more details please get in touch with our sales representative.

iPoint is reviewing the progress and usage of the standards and may support them at some point in the future.

Yes, the iPoint SCIP Database Connector tracks and displays the dossier submission status at all stages of the process. You can track it in the Submission status column in the Submissions search results.

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.

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).

Yes, you can select the TARIC code from the ECHA list available in the iPoint SCIP user interface.

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.

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.

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.

Yes. The iPoint SCIP Database Connector is an add-on to the iPoint Compliance solution. iPoint Compliance already integrates with IMDS. IMDS was changed to hold extra SCIP relevant information. This is now transferred into iPoint Compliance for you to review.