Starting January 5, 2021, companies placing articles on the EU market need to provide information to the EU “Substances of Concern In articles as such or in complex objects (Products)” (SCIP) database on articles which contain Candidate List substances (Substance of Very High Concern (SVHC)) in a concentration above 0.1% w/w. The SCIP database has been established under the EU Waste Framework Directive (WFD, 2008/98/EC amended by Directive (EU) 2018/851) and in addition to the existing obligations for SVHCs under EU REACH.
Information regarding the articles need to be provided by EU producers and assemblers, EU importers and EU distributors of articles and other actors in the supply chain placing articles on the EU market.
Retailers and other members of the supply chain providing articles directly to consumers are not obliged to provide information to the SCIP database.
What must be notified? – Requirements for SCIP notifications
The SCIP notification includes information on article identification (identifiers, name, article category), safe use information, and information on the SVHC in the article itself. The submission of the notification has to be done in a specific SCIP-format using the IUCLID Cloud in the online ECHA Submission Portal. The notification is required regardless of volume of SVHC placed on the market.
What is an article?
According to REACH, an article is an object which during its production is given a special shape, surface or design which determines its function to a greater degree than its chemical composition. A “complex object” is an object made up of more than one article. Articles that are assembled or joined together in complex objects remain articles, as long as they keep a special shape, surface or design, or as long as they do not become waste.
Important note: Packaging is also considered an article under REACH.
Our SCIP Services
- Portfolio Analysis: determining which products in your portfolio are considered articles or contain articles
- Article Information Review: reviewing all available compliance information (i.a. compliance statements, safety data sheets, test reports, etc.) to identify potential SVHCs in your articles
- SVHC Likelihood Assessment: verifying the likelihood of finding SVHCs in your articles, based on the raw materials used
- Data Gap Analysis : detecting possible data gaps and specifying recommended actions to close them
- SCIP notification strategy, including intelligent testing strategies for SVHCs
- SCIP notification dossier: compiling SVHC information in IUCLID format and submitting it to the ECHA
Important note: The candidate list is updated every 6 months. Parts of this process have to be repeated every 6 months to determine new data gaps.