Answers to Common Questions
ECHA maintains an in-depth list of common questions and answers, but you may have more high-level questions that need answering first. Succinct answers to the most common questions are included below, with answers that are tailored to the needs of the electronic industry, where possible.
What's the point of the SCIP database?
According to ECHA, the SCIP database is designed to eliminate the usage of SVHCs in articles by replacing them with safer alternatives. By creating a reporting burden on companies who sell products that incorporate SVHCs above the specified 0.1% w/w threshold, SCIP is intended to discourages the design and manufacture of those products.
The database may more directly benefits waste operators, who can modify their waste separation and recycling techniques based on the potential hazards of the products they are recycling. Those techniques can then be made safer for the operators themselves. This is also intended to reduce the chance that SVHCs wind up in recycled products, where they may be harder to track and may harm manufacturing workers and end consumers.
The SCIP database is intended to allow consumers to research the products that they purchase and will further disincentivize companies to design and manufacture products with SVHCs.
The WFD is also intended to help achieve goals set forth in the EU Circular Economy Action Plan, which places sustainability benchmarks at every step of a product's lifecycle, most notably end-of-life and recycling.
Is the SCIP database different from REACH?
YES - they are different!
Your company may already register your products with ECHA as part of Registration, Evaluation, Authorisation and Restriction of Chemical Substances (REACH). However, while both the SCIP database and REACH place reporting obligations on Candidate List SVHCs, they are different.
Completing a SCIP submission does not fulfill the communication obligations set forth in Articles 33 and 7(2) of the REACH Regulation. In other words, just because you have completed your SCIP obligations, it does mean that you have completed your REACH obligations.
If your product does contain concern substances, you may be able to avoid duplicating work in preparing for both REACH and SCIP. Working with compliance professionals or choosing the appropriate compliance tool can help you navigate multiple legislative requirements. A list of IPC-verified compliance tool solution providers is available below.
Scoping your products - articles and complex objects
While determining if you have obligations to report, you will need to determine if any articles within your products contain Candidate List SVHCs above 0.1% w/w. Therefore, it is important to know what an ‘article’ is in the context of your product.
The Scope of SCIP
The SCIP database is only concerned with articles, articles as such, and complex objects. A ‘product’ is considered by ECHA to be anything ‘placed on the market’, which includes mixtures and substances, which are not in the scope of SCIP.
What is an article?
Article 3(3) of the REACH Regulation defines an article as ‘an object which during production is given a special shape, surface or design which determines its function to a great degree than its chemical composition.’
In this context, ECHA considers the ‘function’ of an object as being the intended purpose for which an object is used. The ‘shape, surface and design’ of an object are those characteristics deliberately imparted onto the object by its design, as opposed to physical characteristics that result from the chemistry of the material(s) that the object is made of.
ECHA has prepared a flowchart to help you determine if an object is an article. Within your product, if you determine that any constituent object is not an article, then it does not fall under the scope of SCIP.
What is a complex object?
ECHA defines a complex object as an object that contains two or more components, each of which is either an article as such or a complex object.
For complex products, there can be many levels of complex objects that need to be reported to SCIP, with critical product information coming from every tier of your upstream supply chain.
SCIP information requirements
In order to be compliant with the WFD, ECHA requires the following information from any company submitting to SCIP:
- Information that allows the identification of an article
- The name, concentration range and location of the Candidate List Substance(s) present in their article
- Other information to allow the safe use of the article, notably information to ensure proper management of the article once it becomes waste.
These high-level information requirements are broken into specific fields that populate the database.
Submission to SCIP is not as simple as submitting a single XML file to ECHA, and care must be taken to appropriately format the SCIP 'Dossier'. A Dossier consists of a compressed archive containing a manifest, product chemicals information across multiple files, and then any attachments.
Elaborating on every required and optional field within the datasets above is well beyond the scope of this resource page. It is highly recommended that you or someone in charge of preparing compliance statements for your company review the SCIP Notification Format Preparation Guide produced by ECHA. If you plan to build software to create SCIP Dossiers 'in-house', then you will also need to review the IUCLID i6z Format Developers Guide.
There are many compliance tools that can help your company accurately capture the necessary information from your product to be made into a SCIP Dossier. Some of those companies are listed below.
Additionally, it is imperative that you request the correct information from your suppliers, and push the correct information to your customers, so that you (or any other duty holders in your supply chain) can accurately submit to SCIP. This kind of declaration can be accomplished with the IPC-1752B and IPC-1754Am2 standards, discussed below.
The cost of submitting to SCIP
Creating and submitting SCIP notifications via the ECHA Cloud Services is free. In order to access ECHA Cloud Services, you must first establish an ECHA Account - all SCIP submissions must be associated with a Legal Entity in the EU.
The real cost of submitting to SCIP lay in the preparation of the Dossier, largely in the person-hours needed to gather and compile product information from suppliers, build the Dossier (if not using a third-party service) for your product(s), and submit to SCIP. For some industries with complex products, this undertaking can be very resource-intensive.
What is the penalty for not submitting to SCIP?
The European Commission has directed that each member state interpret the WFD and related legislation to determine their own penalties for non-compliance.
As of now, there are no finalized penalties for failing to submit into the SCIP database by any member state. This page will be updated to reflect any changes that may occur as states determine penalties.
Will preparing my product information now make my company more competitive in the long run?
Most likely, yes.
As the EU member states ratify penalties for noncompliance, OEMs and other distributers in the EU will likely begin to contractually obligate their suppliers to provide product information that is relevant to SCIP. Being 'ahead of the curve' by preparing your product declarations for your customers and submitting product information to SCIP to be referenced by your downstream will offer your company a competitive advantage as others try to catch up.
Once you have determined your reporting obligation, you must collect your product data, including data from your suppliers, and format it as necessary.
The IPC-1752B Materials Declaration Standard is applicable to products across all industry sectors and helps companies who want to collect data from their supply chains in a format matching the data requirements of the SCIP database. The structure of the IPC-1752B standard mirrors the ECHA SCIP database submission format. The standard includes new functionality which enables reporting different products with different types of materials declarations, known as declaration classes, in the same XML file. This enables suppliers to report sub-products using different declaration classes which provide different levels of detail about the materials in the articles.
IPC-1752B is available in the IPC Online Store at https://shop.ipc.org/IPC-1752B-English-D
As of 2 December 2020, IPC-1752B has already been used to complete upwards of 30,000 submissions to SCIP from a wide variety of industries.
IPC-1754 Materials and Substances Declaration for Aerospace and Defense and Other Industries establishes the requirements for exchanging material and substance data for products between suppliers and their customers for Aerospace and Defense and other industries with deep supply chains and complex bills of materials.
This standard covers exchanging data on chemical substances (“Substances”) that may be present in materials and processes used in production, operations, maintenance, repair or overhaul/refurbishment of the supplied product or sub-product.
The IPC-1754 standard supports a broad range of hazardous substance regulations (like EU REACH, China RoHS or USA TSCA) and obsolescence risk management by establishing rules for software providers, allowing them to track substances present in products and processes against a Declarable Substance List (DSL).
IPC-1754Am2 Materials and Substances Declaration for Aerospace and Defense and Other Industries, published in 2020, is available in the IPC Online Store at https://shop.ipc.org/IPC-1754-AM2-English-D
Third-Party Support: IPC-175x-Compliant Software Tool Vendors
The IPC-1752B and IPC-1754Am2 standards both describe XML schema that enable fast and efficient communication of product data between trading partners. (You can learn more about IPC's standards by watching the videos above.)
In order to ensure that a vendor's compliance tool can read and write valid IPC-1752B and IPC-1754Am2 XML, IPC conducts annual solution provider XML reviews to verify their tool. These reviews are conducted by a panel of industry experts with years of experience in compliance, software development, and IPC standards development. Submissions are kept anonymous throughout the process.
Please note that the following pages do not constitute a full list of vendors who offer compliance tools, nor does it necessarily represent a full list of tools that support IPC-1752B or IPC-1754Am2. However, IPC urges caution when using non-verified third-party tools to exchange data using IPC standards.
Note on the IPC-1752B verification:
IPC-1752B was released earlier this year, and the inaugural IPC-1752B Solution Provider Review will complete by March 2021.
In the meantime, while it is possible to build a SCIP declaration using the IPC-1752A-Wam1,2,&3; it is not as purpose-built as the IPC-1752B and you may need to use more custom fields.