In the context of the Waste Framework Directive, ECHA will establish the Substance of Concern in Products (SCIP) database in 2021. Suppliers of articles need to provide information to this database on those articles which contain Candidate List substances in a concentration above 0.1% w/w as from January 5, 2021.

Recently, The ECHA released SCIP prototype test version. The SCIP prototype is available to support duty holders who want to get familiar with preparing SCIP notifications and test the submission functionalities before the process officially starts at the end of October 2020. All data submitted to ECHA on the SCIP prototype is considered test data, and will not be treated as real data to fulfil legal obligations. All submitted data will be deleted before the October 2020 SCIP database release.

Q1:  What is the SCIP database?

BACL: SCIP is the database for information on Substances of Concern In articles as such or in complex objects (Products) established under the Waste Framework Directive (WFD).

Q2: What are the objectives of the SCIP database?

BACL: The three main objectives of the SCIP database：

• Decrease the generation of waste containing hazardous substances by supporting the substitution of substances of concern in articles placed on the EU market;

• Make information available to further improve waste treatment operations;

• Allow authorities to monitor the use of substances of concern in articles and initiate appropriate actions over the whole lifecycle of articles,;including at their waste stage.

Q3: Which suppliers of articles have the obligation to provide information to ECHA?

BACL: The obligation 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.

The following suppliers of the articles need to provide information to ECHA:

• EU producers and assemblers;

• EU importers;

• EU distributors of articles and other actors who place articles on the market. 

Retailers and other supply chain actors supplying articles directly to consumers are not covered by the obligation to provide information to ECHA.

Q4: What if I am an articles supplier from outside of the EU?

BACL: The responsibility for fulfilling the obligation of providing information to ECHA lies with the EU importers.

Companies outside of the EU are not subject to this obligation and are not allowed to submit SCIP notifications.

Importers of articles in the EU however, need to turn to their non-EU suppliers of articles and request information that they need to fulfil their regulatory obligations, such as the obligation to provide information to the SCIP database. As a non-EU supplier of articles, you should support your EU customers by providing them the necessary information about the presence of Candidate List substances in your supplied articles.

An EU importer may set up contractual agreements with their non-EU suppliers of articles to act on their behalf, regarding the submission of data to the SCIP database. However, the responsibility of the SCIP notification and its content still lies with the EU importer of articles. Please be aware that the third party users will see the same information as all other users in the ECHA IT Tools.

Q5: What information needs to be communicated to ECHA?

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

• administrative contact details;

• information that allows the identification of the article;

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

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

Q6: From which date should information be communicated to ECHA?

BACL: As from 5 January 2021, information on articles containing SVHCs (on the Candidate List) in a concentration above 0.1% w/w placed on the EU market needs to be notified to ECHA.

Q7: What's the difference between REACH notification& communication and SCIP duty？

BACL: There are notification and communication obligations under REACH for suppliers of articles containing SVHCs.

However, it is important to note that the SCIP is established in the context of the Waste Framework Directive, not the REACH regulation. Therefore, the fact that actors supplying directly to consumers are exempt from the duty with regards to SCIP does not affect the existing communication and notification obligations under the REACH regulation.  Suppliers of articles that contain Candidate List substances in a concentration above 0.1% w/w need to communicate to the recipient of the article even when they have no duty to provide information to the SCIP database.

Q8: Which tools will be available for preparing and submitting information to the SCIP database?

BACL: ECHA will make available the submission tools for preparing and submitting information to the SCIP database. The submissions to the SCIP database can be prepared in the most suitable way, depending on your specific business needs and your IT systems:

• Online in IUCLID Cloud;

• Offline in IUCLID;

• Using a IUCLID-compatible dedicated format for SCIP submissions in your company’s own system.

The information to the SCIP database (dossiers) can be submitted through the ECHA Submission portal in one of two ways:

• Online through the ECHA Submission portal;

• Through a system-to-system (S2S) transfer from the company’s own system to the ECHA • Submission portal for submissions (dossiers) created in your own system.

The following guide "How to Prepare and Submit SCIP Notification Dossiers" for reference:   

https://echa.europa.eu/documents/10162/28213971/SCIP_Database_Notifications.pdf/63a1dbe6-20ce-2e37-46be-4293c809dc2f

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