Understanding the SCIP Database and the Connection with EU REACH Regulations

The Substances of Concern in Products (SCIP) database was established under the European Union (EU) Waste Framework Directive (WFD) after its revision in 2015. This initiative is designed to ensure that information on Substances of Very High Concern (SVHCs) is accessible throughout a product's lifecycle, particularly at the waste stage. The SVHCs that must be reported to the SCIP Database are identified under the EU Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) regulation. Companies that fall under the scope of REACH are also required to comply with WFD and SCIP database reporting requirements.

As of January 5th, 2021, all EU manufacturers, assemblers, distributors, and importers must adhere to the SCIP database reporting requirements as set by the European Chemical Agency (ECHA). Understanding the differences between SCIP and REACH reporting is crucial for ensuring ongoing compliance with both regulations. Below, we explain the distinctions between the SCIP database and REACH regulation reporting requirements.

SCIP vs. EU REACH: Key Differences and Similarities

Whar is the Purpose of SCIP and EU REACH

The REACH regulation aims to protect human health and the environment from risks posed by chemicals, particularly those restricted under the regulation. It focuses on reducing the use of hazardous chemicals at the design phase of product development. In contrast, the SCIP database extends the objectives of REACH by addressing the impacts of waste materials containing SVHCs. The purpose of SCIP is to provide detailed information to waste operators and consumers about how to properly recycle and dispose of products containing these substances.

While REACH emphasizes reducing hazardous chemicals during product manufacturing, SCIP focuses on the end-of-life management of these products, encouraging safer disposal and recycling practices. Both SCIP and REACH share a common goal of promoting the use of safer alternatives in products placed on the EU market.

Reporting Requirements: SCIP vs. EU REACH

Both the SCIP Database and the EU REACH regulation require companies to report the presence of SVHCs in their products. However, the reporting requirements for SCIP are more extensive compared to those for REACH.

EU REACH Regulation Reporting Requirements

Under REACH Article 33, companies within the EU, including manufacturers, producers, assemblers, and importers, must declare the presence of SVHCs in their articles when the concentration exceeds 0.1% weight by weight (w/w). To comply with REACH, companies are required to provide the names of the SVHCs present and any relevant safe use information.

• Flexible Reporting: There is no standardized template for REACH reporting. Companies can submit a variety of documents, such as declarations, safety data sheets, certificates, and test reports, as valid data for REACH compliance.
• Usage of Data: The data collected under REACH is intended for use by other actors in the supply chain who incorporate the parts into their products, as well as by consumers purchasing the final product.
• Regular Updates: The REACH SVHC list is updated twice a year, necessitating continuous data collection throughout the year to maintain compliance.

SCIP Database Reporting Requirements

Companies that fall under the scope of REACH are also subject to SCIP reporting requirements. Similar to REACH, SCIP requires companies to report SVHCs present in articles above the 0.1% w/w threshold. The SVHCs reported under SCIP are based on the REACH SVHC candidate list and must be reported at the article level.

However, SCIP demands more detailed information compared to REACH:

• Standardized Reporting Template: SCIP reporting must be done through a specific template called a SCIP dossier. This standardized approach ensures consistency in the data submitted to the ECHA.
• Additional Data Requirements: SCIP reporting requires more comprehensive information beyond what is required for REACH. Companies must provide details on the exact articles containing SVHCs, where these substances are located within the product, and the material composition of the article.
  • Material Identification: Companies must identify the material in which the SVHC is present, such as polymers, metals, or adhesives.
  • Article Category and Numbers: Detailed information on the article category and specific article numbers must be included in the dossier.
• Submission Methods: SCIP dossiers can be submitted manually through the ECHA Submission Portal or automatically via system-to-system (S2S) transfer. Once submitted, each dossier is assigned a unique SCIP number and is publicly listed in the SCIP database, where waste operators and consumers can access the information at any time.

Reduce SCIP Compliance Uncertainty with Acquis

Navigating the complexities of SCIP compliance can be challenging. Partnering with Acquis helps reduce uncertainty and streamlines the data collection and reporting process. Our SCIP program is designed to collect data from suppliers, including the most recent REACH SVHC and SCIP article data, along with supporting documentation. Our team of regulatory experts meticulously reviews this data for completeness and quality, ensuring that your SCIP reports are accurate and comprehensive.

How Acquis Can Help:

• Expert Data Management: Acquis handles the entire data collection process, gathering essential information from your supply chain and verifying its accuracy.
• SCIP Dossier Preparation: We generate SCIP dossiers using the approved template, ensuring all required data is included. Our team conducts gap analyses to identify any missing information before submission.
• Compliance Monitoring and Support: Whether you need ongoing management of your SCIP compliance processes or dynamic software to support your compliance goals, Acquis provides tailored solutions that fit your needs.
• Efficient Submission and Follow-up: We manage the SCIP submission process from start to finish, including dossier submission via the ECHA portal or through automated system-to-system transfers. Post-submission, we handle any follow-up required to ensure successful compliance.

With Acquis, you can trust that your SCIP compliance is in expert hands. Our comprehensive approach not only simplifies the compliance process but also ensures that your company remains aligned with EU regulatory requirements.

For more information or assistance with SCIP compliance, contact our compliance experts at Acquis. We're here to support your compliance journey every step of the way.