SCIP FAQ

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. 

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

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.

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

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.

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 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.

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.

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

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.

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.

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.

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.

Yes.

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 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.

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.

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.

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.

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.

Yes.

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.

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.