People often confuse SCIP and REACH for the same reason they confuse most regulatory acronyms. They sound related, they involve the same EU agency, and they target the same chemicals at the same threshold.
However, they are not the same thing. Treating one as a substitute for the other is a common mistake. It is one of the main reasons a company that looks compliant on paper can fail a real compliance audit.
This article explains clearly what each duty does, where they overlap, where they differ, and what you must do when both apply to a product you sell on the EU market.
Confirming which duties apply to your products is a core part of our REACH compliance services. However, we also want to offer this guide if you want to confirm your REACH and SCIP duties yourself.
REACH is the main EU regulation for chemicals (Regulation (EC) No 1907/2006). It stands for Registration, Evaluation, Authorisation and Restriction of Chemicals and covers the manufacture, placing on the market and use of chemical substances in the EU.
Under REACH, manufacturers and importers generally have an obligation to register substances that they manufacture or import in quantities of 1 tonne or more per year, subject to the scope and exemptions of the Regulation. REACH also includes specific obligations for substances of very high concern (SVHCs), including when they are present in articles.
SCIP is a separate notification obligation under EU waste legislation. It is based on Article 9(1)(i) of the Waste Framework Directive (Directive 2008/98/EC, as amended).
The SCIP notification obligation applies when an article placed on the EU market contains a substance on the SVHC Candidate List at a concentration above 0.1% by weight. In such cases, companies covered by the SCIP obligation must submit information about the article and the SVHC to ECHA’s SCIP Database.
In other words, REACH and SCIP can apply to the same product, but they are based on different obligations and thresholds. The 0.1% threshold is relevant to the SCIP obligation, while the 1 tonne/year threshold is a key threshold for REACH substance registration.
However, the submissions are done in different portals, need different information, and serve different purposes:
REACH is famous for substance registration. Every manufacturer or importer who brings one tonne or more of a chemical substance into the EU per year must register it with the European Chemicals Agency (ECHA).
If you supply finished products (articles), the most important parts of REACH are two specific legal obligations tied to the SVHC Candidate List:
If your product contains an SVHC above 0.1% w/w, you must give your business customers enough information to use it safely. At a minimum, you must provide the name of the substance. Private consumers can also request this information, and you must answer them within 45 days. This communication is private and travels directly through your existing business supply chain.
You must notify ECHA if you produce or import a product that contains an SVHC above 0.1% w/w and the total volume of that specific chemical across all your products exceeds one tonne per year. You must submit this notification within six months after the chemical is added to the Candidate List.
The Candidate List updates about twice a year. Every update can suddenly pull your existing products into scope, even if your manufacturing process did not change at all.
SCIP stands for Substances of Concern In articles, as such or in complex objects (Products). The SCIP database is established under the Waste Framework Directive, which collects information on Substances of Very High Concern (SVHCs) present in articles as such or in complex objects. It allows waste operators, recyclers, and consumers to see exactly which products on the EU market contain REACH Candidate List SVHCs.
This legal duty does not come from REACH. It comes from the EU Waste Framework Directive, specifically Article 9(1)(i), which was added in 2018 (Directive 2018/851). The first notifications became mandatory on January 5, 2021.
The logic behind it is simple: when a product becomes waste, the people recycling or treating it need to know what chemicals are inside so they can handle it safely.
Any supplier who places a product on the EU market containing a Candidate List SVHC above 0.1% w/w must submit a SCIP notification for that product. This rule applies to products made inside the EU and products imported into the EU.
The data you must submit goes far beyond REACH Article 33. You must provide:
The SCIP database is fully searchable by the public on ECHA’s website. You should plan for this public visibility from the very start.
The two duties share the exact same chemical list and the same 0.1% threshold. Almost everything else is different.
| Dimension | REACH (Article 33 & Article 7(2)) | SCIP notification |
|---|---|---|
| Legal Basis | Regulation (EC) No 1907/2006 | Waste Framework Directive 2008/98/EC, Article 9(1)(i) |
| Purpose | The REACH Regulation aims to protect human health and the environment from chemical risks, specifically through Article 33 by ensuring the safe use of products for businesses and consumers. | To inform waste operators and consumers across the product's full life cycle. |
| Trigger | An SVHC above 0.1% w/w in a product. (Plus a 1-tonne annual limit for Article 7(2)). | Any SVHC above 0.1% w/w in a product supplied on the EU market. |
| Who Gets the Info? | Article 33: Business customers (and consumers upon request). Article 7(2): ECHA. | ECHA's public SCIP database. |
| Level of Detail | Chemical substance name plus safe-use instructions. | The Waste Framework Directive references REACH Article 33 regarding the information required for SCIP notifications, with ECHA defining the exact data fields that must be submitted |
| Visibility | Private business-to-business or business-to-consumer data. Article 7(2) stays with ECHA. | Fully public and searchable online. |
| Deadline | Article 33: At the time of supply (or 45 days from a consumer request). Must be kept updated. Article 7(2): Within 6 months of the chemical being listed. Must be kept updated. | Before or at the time the product is first supplied to the EU market. Must be kept updated. |
| Main Exemption | Very few exemptions exist. | Retailers who sell products directly to consumers are exempt from SCIP notifications, but not from REACH Article 33. |
For articles containing a Candidate List SVHC above 0.1% w/w, the REACH Article 33 and SCIP obligations can apply to the same product when it is placed on the EU market, but they impose different requirements.
This is incorrect. The duties are layered. A SCIP notification fills a public database for waste management workers. Article 33 information must still be sent directly to your business customers and given to consumers who ask for it. You have different audiences and different content requirements. You must do both.
This is also incorrect. SCIP puts highly detailed technical data into a public database. Article 33 passes clear, practical safe-use instructions down your commercial sales chain. They do two entirely different jobs.
SCIP applies to every physical product placed on the EU market that crosses the chemical threshold. There are no exemptions for specific industries or sectors. The only real exemption is the narrow rule for retail stores selling directly to consumers.
This is mostly true, but it has a catch. ECHA guidance says retail stores selling directly to private consumers do not have to file SCIP notifications. However, they still have to follow REACH Article 33. Furthermore, the definition of a "retailer" is very narrow. If your company sells products to other businesses—even if you also sell to consumers—you are a supplier under SCIP rules and must submit notifications.
An EU-based electronics manufacturer approached Chementors in 2023, after successfully submitting their product data to the ECHA SCIP database. The company incorrectly assumed that because their chemical data was now publicly available on the portal, their duties under REACH Article 33 were automatically fulfilled. They believed that direct, private communication with their business-to-business (B2B) customers regarding Substances of Very High Concern (SVHC) was now redundant or optional.
Chementors stepped in by clarifying that the SCIP database (under the Waste Framework Directive) and REACH Article 33 (under the Chemicals Regulation) are separate legal duties that run in parallel. While they share the same 0.1% w/w trigger threshold, a public SCIP filing does not replace the strict REACH obligation to actively provide safe-use information directly to buyers upon delivery. Chementors swiftly established a standardized communication protocol for the client, ensuring they fulfilled both their supply chain obligations and waste management requirements without facing non-compliance risks.
If your products contain SVHCs, use this workflow. The order of these steps is critical: you must find out exactly what is inside your products before you start any compliance paperwork.
ECHA updates this list about twice a year. Subscribe to regulatory feeds and check your products every time the list changes.
Check your bills of materials (BOMs), ask for supplier declarations, or use laboratory testing if you lack clear evidence.
For every product that crosses the 0.1% w/w threshold, create safe-use information for your business clients. Set up an internal process to answer consumer queries within 45 days.
If the total weight of an SVHC across all your sold products exceeds one tonne per year, submit your official notification to ECHA within six months of the chemical being listed.
File a separate notification for every single product that is over the threshold. You can use IUCLID app or ECHA Cloud. If your products share similar structures, you can reuse data to speed up the process.
Run this screening process every time ECHA updates the Candidate List. A product that was perfectly clean last month can suddenly fall into scope during the next update.
A complex object is a large product made by joining smaller products together. Each individual part containing an SVHC above 0,1% w/w should have SCIP notifications done by their manufacturers. The main complex object file then links to those parts. A complex object itself therefore requires just a single SCIP notification.
If you import finished products into the EU, you are legally considered the supplier who places them on the market. This means all three compliance duties (Article 33, Article 7(2) if triggered, and SCIP) belong to you, not to your non-EU manufacturer.
The SCIP retailer exemption is very narrow. It only protects companies that sell products exclusively to private consumers. If you sell to any other businesses, you must file. Distributors, white-label suppliers, and brand owners who sell B2B are fully required to comply.
An Only Representative appointed under REACH Article 8 takes over the substance registration duties for a non-EU manufacturer. However, an OR cannot handle SCIP duties. The legal responsibility for SCIP stays entirely with the EU business that imports or distributes the product.
No. Although they are linked, SCIP is a notification duty under the EU Waste Framework Directive. It uses the exact same chemical list and 0.1% threshold as REACH, and you send the data to ECHA, but it is an entirely separate directive with its own distinct purpose.
No. Article 33 communication is a parallel REACH duty. Both laws apply at the same time when a product crosses the 0.1% w/w threshold. They serve different audiences and require different information.
Any company that sells a product on the EU market containing a Candidate List SVHC above 0.1% w/w. This includes EU manufacturers, importers, distributors, and brand owners who sell to other businesses. Retail stores selling only to consumers do not need to file SCIP, but they still must follow REACH Article 33.
Yes. Anyone can search SCIP notifications on ECHA's official database. Keep this public visibility in mind when writing your product names and identifiers.
Individual EU Member States enforce these rules, so penalties vary by country. Consequences might include administrative fines, a ban on selling your products in that market, and public reputational damage if a non-compliant product is found during an inspection.
REACH and SCIP can be triggered by the same substance in an article, but they lead to different legal obligations. The most efficient way to stay compliant is to screen your inventory once, then split the data into two separate workflows: safe-use communication for REACH, and database filing for SCIP. If you do not know whether these laws apply to your products, finding that answer is your very first step.
You can contact our REACH compliance team to start a scoping conversation, or request a free initial consultation. We will look closely at your specific products and map out your duties together.
Chementors has managed EU chemical compliance since 2012. We work daily with substances, chemical mixtures, and finished products, and we have successfully completed more than 250 REACH registrations. We also have extensive expertise in SCIP notifications and the obligations under the Waste Framework Directive. The steps outlined on this page are practical, real-world tasks, not just regulatory theory.