SCIP Article notification

On 11th, September 2018 a news was announced by ECHA that was demanded to establish a Substance of Concern in Product database for collecting SVHC information in Article*1 and publishes SVHC related information to waste operator and consumer, more details related to SCIP database can be found below:

• Purposes:

  • Raising supplier awareness of their obligation
  • Raising consumer awareness about substances of high concern (SVHC) in articles
  • Provide information to further improve waste treatment operations
  • Allow authorities to monitor the use of substances of concern in articles
  • Decrease hazardous waste generation by supporting the substitution of substances of concern in articles

• Legal sources:

  • REACH regulation (EU) 1907/2006 -Article 33
  • Waste Framework Directive (EU) 2018/851- article 9

• Duty holders:

  •  Duty holder means who places the article or complex object on EU market, for example:
    EU producers, EU assembler, importers, EU distributors, but not covers actors in supply chain who directly provide the product to consumer.

  • According to SCIP FAQ, Non-EU supplier needs to provide the necessary data to EU importer and assist the EU importer to comply with the obligation under REACH. 

• Non-duty holder:

  Actors in supply chain who provides the Article/ complex object directly to consumer, like EU retailer. 

• Triger points for SCIP notification:

  Article imported in EEA contains SVHC listed in SVHC candidate list in a concentration higher than 0.1%

• Effective date:

  • If the product has been placed on the EU market before 5th, Jan 2021 and will continue to be provided in the future, the duty holder should complete the submission of the SVHC dataset to the SCIP database by 5th, Jan 2021.

  • As from 5th, Jan 2021, if new SVHC is included into SVHC candidate list and new SVHC concentration in the article is >0.1%, the duty holder needs to update the previous submitted file or submit new SVHC dataset to the SCIP database before the next supply or next placement on EU market. 

• How to create and submit i6z file to SCIP database:

  • First, the duty holder needs to create an account by ECHA if the duty holder doesn’t have it before and then input SVHC dataset into IUCLID 6 in order to create i6z file. IUCLID 6 has 3 different versions, IUCLID 6 cloud, IUCLID 6 desktop and IUCLID 6 server. If SVHC dataset passes validation, please export i6z file and login ECHA submission portal and upload it. Final the duty holder will receive a submission report that summarizes the submitted case. ECHA also provides system to system (S2S) to support companies who wants generate i6z file in own system and submit i6z file to SCIP database in an automated way.

  • Concept is article centric, in other words, all SVHC > 0.1% needs to be included in one i6z file if an article contains more than 1 SVHC >0.1%. 

• Data requirements:

Submitted data has 2 types, one is obligatory, the other one is optional. More details can be found in page 7 to 14 of Guidance “Detailed information requirements for the SCIP database”.

• SGS services:

  • Assisting create i6z file for SCIP notification
  • Consultant service

• Reference:

  • Detailed information requirements for the SCIP database, September, 2019
  • ECHA SCIP database:https://echa.europa.eu/scip-database
  • IUCLID cloud:https://ecs.echa.europa.eu/cloud/home.html
  • ECHA submission portal:https://test-env.ecs.echa.europa.eu/cloud/submissions/ 

Remark:
*1:definition of Article: EU court has provided it decision (Case C 106/14) to explain the definition of Article on 10th, September 2015. In simple way to express: An article is a homogenous object that has a special sharp, surface or design, for example, screw, Lead frame of IC, metallic pin of electronic components.