SCIP notification service

To legally place your product on the EU market, the information on substances of very high concern in your products must be submitted to the SCIP database.

The SCIP notification prepared by Chementors Ltd helps open the door to the EU market!

SCIP

SCIP (Substances of Concern In articles, as such or in complex objects [Products]) is the database that contains information on substances of concern in articles as such or in complex objects (i.e., products). SCIP is built under the Waste Framework Directive (WFD) (EC) No. 2008/98.

Under the WFD, from January 2021, companies supplying articles containing substances of very high concern (SVHCs) on the Candidate List in a concentration above 0.1% w/w on the EU market have a legal obligation to submit a SCIP notification to ECHA.

The SCIP notification consists of certain information on the article which will be then published in the SCIP database to make it available to waste operators and consumers.

This transparency on hazardous substances helps consumers make informed purchasing decisions and provides information on how to best use and dispose of a certain product.

SCIP database also encourages and boosts the substitution of hazardous substances for safer alternatives.

Chementors provides SCIP notification service. We handle the process from scratch which includes assessment of which components (i.e., articles) of the product fall into the scope of SCIP.

“Article” and “SVHC” under SCIP

What is an “article” and “SVHC” in the realm of SCIP? Comprehending this definition would help enterprises determine which products are subject to the SCIP notification.

According to Article 3(3) of the REACH regulation (EC) No 1907/2006, an article means an object which during production is given a special shape, surface, or design which determines its function to a greater degree than its chemical composition. Hence, Electronics, automotive, aerospace, furniture, clothes, toys, and all consumer products (simple and complex articles) that have components containing SVHC are subject to the SCIP notification.

Meanwhile, substances of very high concern are chemicals that:

Meet the criteria to be classified as carcinogenic, mutagenic, or toxic for reproduction (CMR) category 1A or 1B following the CLP Regulation (EC) No 1272/2008.
Are persistent, bioaccumulative, and toxic (PBT) or very persistent and very bioaccumulative (vPvB) according to Annex XIII of EU REACH regulation.
On a case-by-case basis, cause an equivalent level of concern as CMR or PBT/vPvB substances.

Scope of SCIP notification obligation

The obligation to submit a SCIP notification covers all articles placed on the EU market containing a substance of very high concern on the Candidate List in a concentration above 0.1 % w/w. 

Who needs to do the SCIP notification? The following suppliers of articles are duty holders under the SCIP notification obligation:

EU producers and assemblers, 
EU importers, 
EU distributors of articles and other actors in the supply chain placing articles on the market.

PRODUCER

DISTRUBUTOR

ASSEMBLER

Data requirements for the SCIP notification

Suppliers of articles need to submit the following information to ECHA:

Data required for SCIP notification

Information that allows the
identification of the article.

Name, concentration range,
and location of the Candidate List substance(s) present in that article

Other information to allow the safe use of the article, notably information to ensure proper management of the article once it becomes waste

SCIP Notification Process at Chementors

Assessing and identifying articles that fall into the scope of SCIP notification obligation. We can check product information such as bill of materials (BOM), product composition and identify possible data gaps.

Gathering all required information on the identification of the article(s) of interest.

Gathering all required information on the SVHC(s) contained in the articles.

Collecting other information to allow the safe use of the articles.

Preparing the notification dossier with our software.

Creating an ECHA account for the submission.

Submitting the notification dossier on the ECHA system.

Generating the SCIP Declaration of Compliance certificate.

Our team consists of experts who have in-depth knowledge of REACH and Waste Framework Directive, and experience in SVHC assessment and SCIP notification. We are here to assist you.

FAQs

Can we, an EU duty holder, appoint a third party to prepare and submit the SCIP notification on our behalf?

Yes, you can. Under SCIP, it is allowed to assign a third party (defined as a “foreign user”) to submit the SCIP notification on behalf of an EU entity. Using the foreign user functionality in ECHA accounts, one can create a link between that third party and the duty holder account.

It should be noted that duty holders will still be responsible for the notification and its content. Duty holders will give the foreign user visibility to the content of their account based on the roles selected. Also, they can remove the foreign user link at any time.

Which submitted data will be published in the SCIP database by ECHA? How about the confidentiality issue?

The submitted information that allows the safe handling and use of articles shall be made publicly available as received on the SCIP database. At the same time, ECHA sets out confidentiality rules in the SCIP database which aims at ensuring the protection of confidential business information where justified. In detail, information to enable figuring out links between actors in the same supply chain will not be published:

The SCIP database does not show the link between a SCIP notification and its submitter by not publishing the name and contact information of the submitter,
Only identification information of top-level entities is published (i.e., identifiers of articles as such or complex objects available to be placed on the market for which a SCIP notification is being submitted), while specific names (i.e., brand, model) or alphanumeric identifiers of components of complex objects are not disclosed.