SCIP Database Solution
Data Services and Software Solution for SCIP Database Submissions
GreenSoft Technology has a solution for EU REACH Substances of Very High Concern (SVHCs) and the SCIP Database as required under the EU Waste Framework Directive.
Our comprehensive SCIP Database solution combines our industry-proven data collection and validation services with powerful GreenData Manager software to deliver a complete SCIP compliance solution.
Our SCIP solution includes:
• Article ID management
• Article and material category validation
• Protection of confidential business information
• True "once-an-article" analysis and reporting
• SCIP dossier management
• Direct SCIP portal submission capabilities
Data Services and GreenData Manager Software
As part of our Data Services, we will collect data on reportable SVHCs from your suppliers, including article and material classifications, and all other information needed for mandatory SCIP data requirements. We will then validate that data for accuracy and completeness.
We also help assess and assign article and material category classifications to the reportable SVHCs in your products when suppliers are unable to supply such classifications.
Using our GreenData Manager with SCIP Module (GDM w/ SCIP) software, we can automatically generate SCIP dossiers for direct upload to the SCIP Database.
Developed by engineers and regulatory experts, GreenSoft's comprehensive Data Services and GDM w/ SCIP software provide the unique ability to validate the contextual content needed for SCIP Database submissions.
Who needs to comply with SCIP?
EU producers/assemblers, EU importers, and EU distributors of articles and other parts in the supply chain who are placing articles on the EU market all need to comply with the SCIP Database submission requirements.
But even companies that are not directly required to comply will often be requested by their customers to provide the necessary data so that the customers can submit their product information to the SCIP Database.
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Your obligations for SVHCs and the SCIP Database
Both the EU REACH regulation and the EU Waste Framework Directive require affected companies to evaluate and communicate or report on the risk of hazardous substances within their products. In order to do this, companies must collect and assess the chemical data of their products and components from their supply chain.
EU REACH Substances of Very High Concern (SVHCs)
Companies with products containing SVHCs over 0.1% w/w at the article level (defined as "reportable SVHCs") have an obligation to notify their down-stream customers.
The list of SVHCs grows and changes every 6 months, so Compliance Statements for components claiming EU REACH compliance have very short lifespans.
The best method for companies to manage the substance data on their products is to collect Full Material Declaration (FMD) data from suppliers so that substances can be re-evaluated without having to recollect data from suppliers every time the SVHC list is updated.
EU Waste Framework Directive (WFD) SCIP Database
As of January 2021, companies placing articles on the EU market which contain reportable levels of SVHCs under EU REACH will also need to submit their product information into the Substances of Concern in Products (SCIP) Database as part of the requirements per the EU WFD.
Submissions to the SCIP Database require significantly more information than EU REACH SVHC communication obligations.
Suppliers of articles with SVHCs over 0.1% w/w need to submit the following information to the SCIP Database:
• Name of the substance and its safe use (originally/currently required under Article 33 of EU REACH)
• Determine the category of the article containing the reportable SVHC (selected from a list of over 20,000 options)
• Determine the category of the material or substance (mixture) which contains the reportable SVHC
• Linking of articles that contain the reportable SVHC within complex objects
• Determine the concentration range of the reportable SVHC within the reported article
• Determine if the article was produced or assembled within the EU
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Data Collection, Validation, & Supplier Guidance
As part of our Data Services, GreenSoft will collect SVHC compliance data from your suppliers. Since the SCIP Database is still new to suppliers, the amount of suppliers who will be capable of providing this complex data (such as article category and material category from a pick list of 20,000 options) without errors is small. We provide guidance and education to suppliers to help improve response rates and data accuracy.
GreenSoft’s data collection team will actively pursue unresponsive suppliers via telephone and email as many times as it takes to obtain the required data. We then validate that data to ensure it is complete and accurate. This person-to-person data collection model allows for validation not only of the presence of the data, but of the contextual content of the data as well.
Keep Your Data Private with Unique Article ID Management
Submissions to the SCIP Database online portal require companies to disclose the articles and locations of articles and substances within their products, as well as the hierarchy of their Bill of Materials (BOM).
This is required for waste processors to identify which articles contain hazardous substances which must be removed for product disposal. But providing this information to a central database puts companies at risk of having their data and trade secrets exposed.
GreenSoft’s SCIP Database solution includes an intelligent unique article ID assignment and management system to keep your trade secrets private. GDM w/ SCIP software generates a displayable name for articles which allows you to supply the required component information, article location, and BOM hierarchy without exposing your sensitive data.
Submissions to the SCIP Database require data to be classified into article categories and material categories from a list of over 20,000 options.
GreenSoft will work with the suppliers to determine the category of articles and category of materials in your products which contain reportable SVHCs, and if suppliers fail to provide category classifications, we will perform classification assessments on article categories and material categories to fulfill the data requirements for SCIP database.
GreenData Manager Software
Our GreenData Manager with SCIP Module (GMD w/ SCIP) software is a powerful tool that allows for complex data processing and article analysis. Companies can use GDM w/ SCIP software to manage their EU REACH compliance and SCIP Database reporting themselves, or GreenSoft’s team can generate reports and SCIP dossiers from GDM w/ SCIP for you.
GDM w/ SCIP software features include the identification of reportable SVHCs in Bills of Materials (BOM), components, articles, and materials/mixtures. GDM w/ SCIP can assist in completing data requirements to prepare SCIP dossiers and export the dossiers into IUCLID i6z format for submissions. You can choose to submit SCIP dossiers one at a time or process them in bulk through a system-to-system transfer to the SCIP Database.
Comprehensive Article Processing
“Once an Article, Always an Article” (O5A) is now an inherent part of compliance with the EU REACH regulation, per the EU Court of Justice ruling in September 2015 (C-106/14).
This means that sub-parts of electronic components are considered articles when complying with EU REACH per the ruling of EU Court of Justice. Failing to evaluate products and components all the way through to the article-level puts your company at risk with violating the EU REACH regulation, losing market access, and disrupting your sales.
Article processing, which the European Chemicals Agency (ECHA) has confirmed is necessary to prepare data for SCIP Database submissions, is difficult and tedious. Any software tool used to validate product compliance for EU REACH SVHC should have the ability to dynamically apply article designations for each material present in a part, as well as have the capability to process complex objects made of multiple materials within the part. But software alone cannot determine the article status of materials. That requires human intervention for construction analysis.
GDM w/ SCIP software is able to designate materials within parts as articles, as well as combinations of materials as complex objects. GreenSoft’s experts oversee this process and provide the context and designations required to meet O5A standards.
GreenSoft is the only solution provider in the industry that offers O5A article processing.
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