SCIP Database │ Frequently Asked Questions
As of January 2021, companies placing articles on the EU market which contain reportable levels of Substances of Very High Concern (SVHCs) under EU REACH will need to submit their product information into the Substances of Concern in Products (SCIP) Database as part of the requirements under the EU Waste Framework Directive (EU WFD).
The following set of Frequently Asked Questions provides information for manufacturers and suppliers to guide you through the most common issues companies encounter when dealing with the SCIP Database.
If I produce purely for export, do I still have to submit to the SCIP Database?
No. Only articles which are placed on the EU market are subject to SCIP notification obligations. Articles produced within the EU purely for export outside of the EU are not in scope.
As a manufacturer for other companies, do we have to report to SCIP?
This will depend on the business relationship. A company producing a product on contract for another company and then selling the product to the EU market could be considered as making the product available on the EU market. However, a company providing manufacturing as a service may not be. We recommend consulting a legal advisor or import/export consultant to review your potential obligations.
We ship products to distributors in the EU including to a few retailers, so who is responsible for the SCIP notification?
Retailers are not obligated to make submissions to the SCIP portal unless they are also acting as the importer or distributor. If they are acting as importer/distributor, then they must make the submission. We recommend reviewing your import/export structure with the recipient of the article to determine which supply chain actors may have such obligations.
Who is the producer of a product that is developed in EU, but manufactured by a contract manufacturer outside the EU?
The location where the product is designed does not constitute production. It is the manufacture location which determines where the product is produced. However, if the manufacturer is contracted to build the product, the developer could assume the responsibility to submit the dossier. This situation will vary depending on the structure of the supply chain and how supply chain actors interact to place the product on the EU market.
What about suppliers outside the EU? What obligations are they facing?
While suppliers outside the EU cannot make submissions to the database, they can still do the same processing as EU suppliers and make this information available to their customers and importers, who will need this information. The only difference is the ability/obligation to submit the information to the database themselves.
Is SCIP registration applicable to products placed on the UK market?
No. We have not heard of any intention within the UK to implement SCIP style requirements. SCIP requirements only apply to products placed on the EU market.
If we are a subcontractor for electronics for customers who put the machines on the market, do we have to submit our modules to the SCIP database? Or is it to be done by our customers?
The legal entity inside the EU placing the product on the market has an obligation to submit a dossier to the database. If you are a producer who produces the product for placing on the market, you may have an obligation as well. This will depend on the nature of the relationship with your customer. If you are simply contracted to build the product, you may not have any obligation. However, your customer may ask you to make a submission, or provide the SCIP data set or dossier to them.
What happens if a company has different divisions across different EU member states in regard to the “one legal entity account per company” requirement of the European Chemicals Agency (ECHA) SCIP portal?
One incorporated business entity within the EU should have one Legal Entity account within the ECHA SCIP platform. If these divisions are incorporated as separate companies, then they could have their own legal entity for SCIP submissions. If they are simply divisions of one company, then they would be covered under the mother company’s ECHA Legal Entity account.
Updating SCIP Submissions
What is the process for updating a SCIP submission considering that the EU adds Substances of Very High Concern (SVHCs) twice per year and may add one that is in our articles?
If a new SVHC is added to the SVHC Candidate List, and the new substance is present in an article within a product you have previously notified to the SCIP database, then simply update your dossier accordingly and resubmit. The SCIP notification will be updated, and the SCIP Reference ID for the product will remain the same.
If I already submitted dossiers (including a subcomponent) to the SCIP database, and later I perform changes on that subcomponent in IUCLID 6 (e.g. its TARIC Code), does it update the already submitted dossiers automatically or do I have to create the dossiers again from the complex object (own product)?
Changes made in the IUCLID tool do not automatically flow to the SCIP database. You must make the changes to the article, then recreate the dossiers for the complex object which contains that article, and submit the new dossiers to the portal.
When a product with a previously submitted SCIP dossier has become obsolete, do we need to do anything to inform ECHA that we no longer import the product to the EU?
No. At this time there is no option to report a product as no longer available on the market. This could be something ECHA adds in the future. However, ECHA does provide the ability to indicate when a previously reported SVHC has been eliminated from a product which was previously notified.
Instead of using a TARIC Code, is it acceptable to use an HTS Code?
The actual code which must be used is the ECHA Category Code from the ECHA-provided pick list. This can be downloaded from the ECHA website. This list mirrors the EU TARIC list, so the TARIC list can also be referenced in determining the code. While HTS/HS codes are similar to their TARIC counterparts in most cases, this is not true in all cases. The EU Trade Helpdesk tool provides the ability to convert HS/HTS codes to TARIC.
If we have a control board in our machine that has components that need SCIP reporting, but the board itself is proprietary and we don’t want the public or competitors to know what is on it, what can we do?
You are not required to reference the component manufacturer names or part numbers when including articles in your product’s dossier. Other unique identifiers are allowed to be used which will reference the articles in generic ways, thus protecting your proprietary information. GreenSoft’s GreenData Manager® (GDM) software utilizes these parameters and ALWAYS assigns Reference IDs to parts, masking supplier names and PNs and ensuring supply chain privacy.
The SCIP portal allows for grouping articles under a single registration. Has GreenSoft incorporated that strategy into their process?
Yes. By including the ability to use the alternate Unique ID data field for each product, products can be grouped as desired by the user. This includes the quasi-identical article grouping methodology recommended by ECHA, as well as the ‘Representative Article’ approach which has been proposed by industry stakeholders.
Are manufacturers required to submit all levels of product structure, not only the parent product and the actual component containing the SVHC?
Manufacturers are required to submit enough information for the end-of-life processor to find the declared article(s). Full Bill of Materials (BOM) information is not required. However, as an example, if an SVHC is present in a gasket within the thermostat of an automobile, simply listing the automobile and the gasket would not be sufficient. Detailing the presence of the gasket within the thermostat, within the intake assembly, within the engine, would allow the end-of-life processor to find the substance of concern during end-of-life processing.
We have a PCB board that contains an SVHC above the threshold and is used in several end products. Do we need to upload all those products in the SCIP database or can we enter it under a product family name?
Every product placed on the EU market which contains an article over threshold must have a corresponding SCIP submission. If the products are similar and all contain the same articles and SVHC profiles (for example, they all contain the same PCB board), then they could be combined into one submission, as long as all group members are uniquely identified, and the top level products are similar enough to be referenced by the same Article ID (TARIC).
Concerning a product containing both simple articles with SVHCs, and simple articles without SVHCs, should I declare the complete BOM of the complex article?
No. Only the top-level product and simple articles with SVHC should be included in the SCIP submission. Any simple articles without reportable SVHC content should be omitted from the SCIP submission.
Which SVHC version do we have to upload in SCIP?
SCIP information should reference the latest SVHC list, as published by ECHA. New SVHCs are added at least 2 times per year to this list, so producers should monitor the content of new SVHCs and update any submitted dossiers if the products are impacted by SVHC list changes. We recommend subscribing to our blog to receive updates on SVHC additions and other regulatory news via email.
How do you handle multiple manufacturer parts (AVL) under a single part used in my design?
Alternate sources can either be included (all sources listed as present), or you have the option of using only the primary parts in the dossier. This is per your preference.
How should we name our products (“unique ID”) in the database? What are the benefits of naming them as they are sold vs anonymized IDs?
Because two of the stated intents of the database are to (1) allow consumers to research information on products, and (2) to allow end-of-life processors to access this information, we would recommend using the product’s part number or model number, as marked on the product.
To what level is reporting required? For example, if an Integrated Circuit in my product contains an SVHC Candidate List substance > 0.1% by weight, is reporting at the Integrated Circuit level sufficient, or do I need to go down the actual location within the Integrated Circuit (such as the lead-frame within the IC)?
This depends on the structure of the item in question. If the first article into which the SVHC was incorporated is the entire IC, then the entire IC should be identified as the article as such. If the SVHC was incorporated into an article within the IC, then the internal article into which the SVHC first incorporated should be identified as the article as such. Details on how to calculate and report SVHCs can be found by reviewing Example 21 of ECHA’s “Guidance on Requirements for Substances in Articles”, available here: https://echa.europa.eu/documents/10162/23036412/articles_en.pdf.
Industrial products with long lifetimes have a lot of modernization & changing spare parts during their lifetime. But isn’t it correct that SCIP requires only information from the time the product is first put on the market?
That is correct. Modifications, updates, and improvements to a previously sold product do not require SCIP submissions. However, the existing submission must still be maintained and updated as the SVHC list changes for as long as you are making new units of the product available on the EU market. The individual units which were already sold do not need to be considered for SCIP compliance. Keep in mind that if you offer upgrades or spare parts on the EU market, you are placing these on the market, so you will need to review obligations to submit based on those spare parts or upgrades. As an example, I could sell a new hard drive as an upgrade to an older PC which I sold previously. While I would not be obligated to update the PC’s SCIP dossier, I would potentially need to create a SCIP dossier for the hard drive which I am making available.
If I have submitted a SCIP dossier to the database for a product which contains an Article with an SVHC, and I need to send a replacement (repair) part to the EU to repair a product previously sold, does that replacement part need its own SCIP submission? Even if the article was already listed in the master product’s SCIP dossier?
GreenSoft has had detailed discussions with ECHA representatives on this topic. The answer is yes: even if the part was included as part of the parent product’s previous SCIP submission, if you send a replacement part into the EU, you are making that part available on the market, and it must have a SCIP notification. The fact it has already been notified as part of another product is not relevant.
Data and Data Collection
We don’t have Full Material Declaration on our products because a few suppliers were not able to provide us with the information. In this case, we don’t have a full material list on the products, including the packaging materials used. How should we treat this situation with respect to SCIP obligations?
If you don’t have Full Material Declaration data on the parts and materials, you must contact your suppliers and collect either SCIP Reference IDs or the data needed to build the full SCIP data set on the articles they are providing, including the reportable SVHC contained in the article. Please also note that packaging materials are evaluated as separate, individual articles, and are not considered part of the product itself.
Is GreenSoft able to handle data collection at a black box level, such as: servers, workstations, network switches, firewalls, etc.?
Yes. Ideally, we would collect the SCIP reference numbers for these items, and reference those as the objects containing reportable SVHCs with your product’s SCIP dossier. If the supplier is unable to provide the SCIP Reference ID, then we would work with the supplier to identify the articles and concern elements contained within the complex objects themselves.
What if an article supplier informed us of an SVHC presence but did not submit a SCIP entry? Does GreenSoft submit for them? How can we reference the article without this entry?
If no SCIP reference number exists for an article within your product, and you are aware the article contains an SVHC over reporting threshold, then we would need to collect and analyze the specific SCIP details (such as article/material categories, SVHC concentration, etc.) for the component, and include that in the data set used to construct the SCIP dossier for your product.
What if the data received from a supplier for a component didn’t go up to the article level? Eg. IC. How can you go to article level without supplier cooperation?
ECHA has advised that we load the data we have available. If we are aware the IC contains an SVHC over threshold, but have no ability to determine the internal article which contains the SVHC, we could load the IC itself as the article as such. However, we should continue to work with the supply chain to fill any gaps in data, so we can update the dossier to include more detailed article information per ECHA guidance.
When will the enforcement of the SCIP regulation start? What are the penalties?
There is currently no indication as to when member states will begin enforcing compliance with SCIP notification obligations. No penalties have been discussed by the member state authorities to our knowledge. For this reason, it makes sense to ensure quality data and correct SCIP dossier structures are submitted, so in the event member states abruptly start applying enforcement activity, risk of non-compliance will be mitigated.
When is the SCIP implementation/enforcement date?
As of January 5, 2021, any articles or complex objects placed on the market within the EU must have a corresponding submission into the ECHA SCIP database if the item contains within it any articles with SVHCs over 0/1% w/w.
SCIP Reference IDs
Do spare parts that are also sold and shipped separately need separate SCIP Reference IDs than the appliances that they are spare parts for?
Yes, if parts are placed on the market for sale, these must be considered separate products being placed on the EU market.
We obtained a SCIP Reference ID, but how will we know if it will be updated when new SVHCs are released?
There is no way to know when a supplier updates their SCIP notifications. However, because the SCIP Reference ID remains constant, once you use their SCIP Reference ID in your product notification, you will always be tied to their most recent submission. Additionally, as you are referencing their submission, you don’t have responsibility for its contents.
Can we create our own Reference number?
No. The SCIP Reference ID number is generated by the SCIP portal at the time the product’s first dossier is submitted. This is an ECHA-generated Reference ID.
How do you address large quantities of BOMs retained in an ERP/PLM system to evaluate SCIP registrations?
Rather than starting from the BOMs, I would recommend starting from the list of products being placed on the EU Market. If you are placing large quantities of individual products on the market in the EU, you may want to consider a 3rd party software solution which can:
(1) Import BOMs directly from the PLM/ERP platform,
(2) Build and submit the SCIP dossiers,
(3) Track your product, its parts and materials, and the SVHC list for changes that might impact submissions, so you can keep the large portfolio of products up to date.
GreenSoft’s GreenData Manager® (GDM) SCIP module does all of this and more.
We have two paths for products to the EU: 1) OEM that has implemented a confusing SCIP entry portal for us to enter the products sold to that particular customer only, 2) EU sales reps & systems integrators. How do we handle this beyond the OEM with the SCIP entry portal?
I assume you are not an EU entity and cannot make submissions to the portal yourself. If that is the case, then the information you are loading into your customer’s 3rd party portal is the same information you will need to provide to your integrators and sales reps. If the products to the portal and the integrators are the same, you could consider sending them the same template that you completed for the portal.
Can GreenSoft integrate our component information with other databases used for collection by other companies?
GreenSoft utilizes the IPC-1752A standard, which provides industry-standard XML protocols for exchanging compliance and substance data between electronic product compliance systems. This allows GreenSoft’s systems to exchange information with any platform supporting this industry standard. Additionally, GreenSoft is planning to implement the latest IPC-1752B standard in Q1 of 2022, which contains the data elements needed to exchange SCIP information. Once deployed, this will allow the exchange of SCIP information between platforms such as GreenSoft’s GreenData Manager® (GDM) software, and other industry compliant platforms.
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Legal Disclaimer: Please note that GreenSoft Technology, Inc. is not a legal firm, and cannot provide any legal advice or guidance. The information provided below is provided for reference and informational purposes only. GreenSoft recommends that any regulatory compliance strategies or processes be reviewed by a legal advisor or attorney.