On January 5, 2021, the Substances of Concern In articles, as such and In complex objects (Products) (SCIP) database will go live. Companies operating in the European Union (EU) must submit data when introducing articles containing Substances of Very High Concern (SVHCs) above the 0.1 percent weight by weight (w/w) threshold.
The reporting trigger for an in-scope article is currently derived from the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation’s Candidate List of SVHCs, but the data requirements for the SCIP database, triggered by the EU Waste Framework Directive (WFD), vary widely from those required by the REACH Regulation.
REACH Regulation Requirements Vs. SCIP Database Reporting Obligations
For companies, the most pertinent difference between the REACH Regulation and the EU WFD lie in the data requirements for companies in scope as outlined in the graphic below:
The data requirements for the SCIP database are more complex than those of the REACH Regulation and require substantial amounts of information from the supply chain. For example, a SCIP dossier must contain substance data as well as company and article information. The substance data includes reference substances, concentration ranges and mixture categories, while other data fields require article numbers, TARIC codes, material identification, legal entity IDs and more.
The database also requires a declaration for articles at every level of the manufacturing process. Dossiers for objects containing one or more articles must link to the dossiers for each lower level articles with SVHCs incorporated into the object, whereas the REACH Regulation requires a single declaration at the parent product level.
Learn how to submit to the SCIP database effectively in our guide, Building an Effective SCIP Database Program.
SCIP Database Objectives
The SCIP database’s purpose is to reduce the amount of hazardous waste by supporting the use of replacement substances in articles entering the EU. The database will be used by downstream waste processors to ascertain important information needed to protect themselves during the waste treatment process. It will also allow authorities to monitor the use of hazardous substances in products and determine the appropriate actions for these products across their lifespans, including the waste stage.
The REACH Regulation’s main focus is protecting the public and environment and encouraging the replacement of hazardous substances used in the production of goods. The regulation is heavily focused on the manufacturing stage or the point at which an article enters the market and has little to no impact on the end-use of products.
Companies in Scope
European Union WFD SCIP database requirements impact almost all companies that manufacture or sell products containing SVHCs above the threshold in Europe. The following suppliers of articles need to provide information to ECHA:
- EU producers and assemblers.
- EU importers.
- EU distributors of articles and other actors in the supply chain placing articles on the market.
For non-EU companies selling into the European Economic Area, SCIP database reporting obligations fall to the first importer of record. Importers will require supply chain data from their non-EU partners to fulfill this requirement.
Manufacturers of articles used in the interest of national defense or security may be allowed exemptions as determined by individual member states. Distributors that do not alter a product or article that contains a valid SCIP dossier from a manufacturer or importer do not have obligations to report. Additionally, retailers that sell directly to consumers are out of scope.
The REACH Regulation contains a number of disparate requirements. For example, companies importing over one metric ton of a substance into the EU must register that substance for its use. Companies importing less than that amount have no registration obligation, but must comply with the authorization and restriction rules established by the REACH Regulation.
Companies in certain scenarios may apply for total or partial exemptions and some exemptions are granted without registration. For more information on REACH exemptions, visit here.
How Assent Can Help
Assent’s software automates supply chain data management, enabling companies to more efficiently meet their SCIP database reporting requirements. The Assent Compliance Platform leverages a workflow-driven, programmatic approach to engage the supply chain and identify articles containing SVHCs and retrieve the required data for SCIP dossier submissions. The platform integrates to provide companies with a viable third-party option for submissions. For more information about how Assent can help your company, contact our experts.
