Does your company produce, import, or supply products to the European Union?

If those products contain certain substances of very high concern to human and environmental health, then you may have an obligation to report into the ECHA SCIP database.

Even companies who do not directly supply to the EU may have soon have contractual obligations to provide relevant product information to their customers. Distributers within the EU may also have obligations. Learn more about SCIP below.


 

The European Union (EU) Directive 2008/98/EC on Waste, commonly referred to as the Waste Framework Directive (WFD), entered into force from July 2018. The WFD sets requirements on waste management, recycling, and recovery of products manufactured in, supplied to, or imported to the European Economic Area. As part of these requirements, the WFD mandates that any article containing Substances of Very High Concern (SVHCs) must be declared to the European Chemicals Agency (ECHA) so that this information can be made available to waste operators and consumers.

To aide in this declaration, the European Commission has directed ECHA to create the Substance of Concern In articles as such or in complex objects (Products) database – the ECHA SCIP database.


Any company supplying articles containing SVHCs on the ECHA Candidate List in concentration above 0.1% w/w on EU market must submit information on these articles to the SCIP database from 5 January 2021.


 

Determining your obligations can be challenging, especially if you do not directly manufacture or sell products in the EU. While this resource page is far from exhaustive, it will point you towards other important resources, relevant legislation, and experts and services that can help your company stay in compliance with the WFD.

Remote video URL
The latest information from ECHA
A Comprehensive Introduction to SCIP

ECHA provides periodic informational material regarding SCIP, such as the webinar Get Ready to Submit Your SCIP Notification that originally premiered on 19 November 2020. 

While you are encouraged to watch the entire video, we have condensed the relevant information into timestamped segments, below. You can click on a timestamp to be taken to that spot in the video. (This will open a separate tab to YouTube.)

Introduction and Duty Holders

 

0:00 - Introduction and Webinar Overview 

Clara Rueda, scientific officer at ECHA, gives an overview of the webinar. 


2:12 - SCIP Data Preparation 

Telmo Vieira Prazeres. scientific officer at ECHA, discusses how to prepare to submit data to the ECHA SCIP database. 

The SCIP database is intended to reduce the presence of substances of very high concern in products on the market in the European Union. The goals of the SCIP database can be broken into three main areas: 

  • The SCIP database is intended to push for a substitution of concern substances in products, and thereby prevent the generation of hazardous waste at the end of a product's lifecycle. In turn, both consumers, supply chain workers, and waste operators will be protected from the dangerous handling of hazardous materials. 
  • The SCIP database is intended to increase authorities' information basis of substances in articles available in their local markets. This information can inform regulators in identifying the need for new legislation. 
  • The SCIP database is intended to improve waste treatment options to promote a more circular economy. 

SCIP version 1 opened on 28 October 2020, however the obligation to notify does not happen until 5 January 2021. 


6:35 - Notification Duty

Any supplier of articles containing above 0.1% of an SVHC on the Candidate List must report into SCIP. This includes EU producers or importers, any assemblers of products, and any distributers. This excludes retailers that supply directly and exclusively to consumers. 

It is important to note that Non-EU suppliers are not allowed to submit SCIP notifications. However, importers to the EU should do their best to support their European supply chain by preparing SCIP data. 

SCIP Information Requirements

12:25 - SCIP Information Requirements 

In general, you will be required to submit data about articles and complex objects in your products in high enough detail that any user can identify where concern substances are in the products and how to safely handle the products. 

Data that is required for articles within complex objects: 

  • Identifiers:
    • Article name 
    • Other names, such as the brand or the model number
    • A primary article identifier, such as the EAN, GTIN, catalogue number, or part number
    • Any other identifiers, such as the above 
  • Categorization: 
    • Article Category - CN or TARIC code
    • A statement declaring if the article was produced in the EU 
  • Characteristics: 
    • Manufactured properties of the article, such as dimensions, color, weight, etc. 
  • Safe Use Instructions: 
    • Instructions for handling the article that contains candidate list substances at every stage of the product lifecycle

There are also information requirements for reporting articles only: 

  • Any candidate list substances present in the article 
  • The concentration of that candidate list substance in the article
  • The location of the candidate list substance in the article
  • What the article is made of (i.e., its material), or what candidate list substance was present in a mixture incorporated into the article as a manufacturing process step (e.g., adhesives, coatings, or paints)

 

Data Usage and Confidential Information

19:45 - Target Audiences

The information present in the SCIP database will be made available to waste operators, consumers and other interested parties (e.g., non-governmental organizations), and authorities (e.g., EU member states). 

When preparing your information for SCIP, provide sufficient identifiers such that these target audiences can easily search for your products in the database. Providing a high level of detail will also help your supply chain members in preparing their data. 

The name and primary identifier alone are not likely sufficient to be easily searchable. 

ECHA will publish all information received on its website. The quality of the information is the sole responsibility of each submitter. 


24:48 - Confidential Information

The name of the company submitting information will not be disclosed. Only identifiers and articles notified as such, or identifiers of top level articles within complex objects, will be disclosed. 

The duty holder has the responsibility to not report information that could disclose commercially sensitive information. 

You can review ECHA's privacy policy here.

Grouping - Identical and Quasi-Identical

26:30 - Grouping 

Fully identical articles - those that have the same function, user, physical form, and chemical compositions - can be submitted in a single notification. 

As an example, consider a company that has produced 100 identical screws. Instead of making 100 submissions for each screw, it is sufficient for the company to submit a single notification for all 100 screws, or for any additional identical screw that they produce. In general, this allows companies to make large quantities of a single article and submit one notification.

"Quasi-identical" articles are those that are identical (above), but have different machined dimensions. Extending the example of identical screws; if a company produces a family of screws with different lengths, but the composition of all screws are identical, then the entire family of screws may be submitted in a single SCIP notification. However, it is imperative that the company submit sufficient information that anyone searching for any of the screws can find the notification. 

Recommendation for Grouping of Complex Objects

37:56 - ECHA Recommendations for Hierarchy Grouping of Complex Objects within Supply Chains

ECHA recommends articles (or other complex objects) from suppliers based on hierarchy within the supply chain. For example, consider the simplified supply chain below, taken from ECHA: 

ECHA Supply Chain Example

In this example, when a new assembly is created at each step of the production pipeline, it is considered a new complex object in the scope of building a SCIP notification. 

However, ECHA also urges each industry and supply chain to adapt their own norms for grouping articles into complex objects. Regardless, these definitions must comply with the REACH definition of an article (defined elsewhere) and must convey the necessary information needed for stakeholders to find articles in the SCIP database. 

Pre-Submission Checklist

43:00 - Final Considerations before Submitting 

Before submitting to SCIP using one of the methods detailed below, ECHA has provided some final considerations: 

  • Above all, be transparent about your data. Your data will likely be scrutinized by not only regulators and stakeholders within the supply chain, but also by consumers and consumer advocacy groups. 
  • If your data is faulty or incomplete, it may reflect poorly on your company. 
  • SCIP notifications may require additional information (beyond mandatory information) to properly describe the location, concentration, or safe use instructions for any articles containing candidate list substances in your product. 
  • Make sure that you are using fields correctly. Please see 'SCIP Dossier Creation Example' for more details on mandatory fields. 
  • Avoid submitting the same information multiple times. 
  • Utilize SCIP numbers, provided by your suppliers, to minimize the complexity of your submissions. This is described in 'SCIP Numbers'. 
  • Avoid submitting notifications by mistake, as ECHA is unable to delete or prevent the dissemination of incorrect or incomplete submissions. 
  • Validate your dossiers in the IUCLID application before submitting. 
IT Tools and How to Submit

50:10 - IT Tools 

Before you can submit to SCIP, you must create an ECHA Cloud Services Account and associate your account with a Legal Entity (ie., your company). 

You can submit to SCIP in the following ways:

  • If you would like to prepare your own data, you can submit using the ECHA Cloud Service portal.
  • If you would like to prepare your data offline, you can use the IUCLID 6 desktop environment. 
  • Finally, there is also the option to use system-to-system data transfer between your company's in-house BOM management tool, your compliance software, or other solutions. 

 

Referencing SCIP Numbers and Simplified SCIP Notifications (With Walkthroughs)

58:00 - Referencing SCIP Numbers as Provided by Suppliers

Every submission to SCIP is associated with a unique identifier - the SCIP number - that can be provided to your customers. This SCIP number allows your customers to incorporate your SCIP submission directly into their SCIP submission, without having to duplicate your data. Providing the SCIP number may save your customers time and money by simplifying their supply chain communication. 

When using a supplier's SCIP number, it is imperative to not change the physical form or composition of the referenced object. 

This section contains an in-depth walkthrough of creating a SCIP dossier. 


1:33:59 - Simplified SCIP Notifications 
 

If your company only distributes products, then you may use a Simplified SCIP Notification (SSN) to 'pass along' your supplier's SCIP notification to ECHA. 

In order to complete a SSN, all you need is your Supplier's SCIP Number. Once you complete your SSN, you will also receive a SCIP number, to pass along to your customers. 

This section contains an in-depth walkthrough of creating a SSN.

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.

The scope of the information that is required for submission to the SCIP database, shaded in gray. (Detailed Information Requirements for the SCIP Database, ECHA)

 

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.

Determining if an object is an article. (Guidance on Requirements for Substances in Articles Version 4.0 – June 2017, ECHA)

 

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. 

SCIP Dossier Hierarchy (Preparing a SCIP Dossier, ECHA)

 

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. 

Preparing your product data for submission to ECHA SCIP, your customers, or both

Once you have determined your reporting obligation, you must collect your product data, including data from your suppliers, and format it as necessary. 

IPC Standards as Compliance Tools
Utilizing IPC-1752B Materials Declarations for SCIP Compliance

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. 

In a recent technical paper published by Proactive Alliance, the following statistics were reported regarding the IPC-1752B standard and its applicability and usage for preparing data for SCIP:

On 16 December 2020, ECHA reported that, 50 days after the launch of the SCIP database, companies across Europe have submitted a little over 2 million notifications. As highlighted in the database, 97% of these notifications to the SCIP database have used the IPC-1752B standard to collect Full Materials Declarations and Regulatory Compliance Declarations from company supply chains. You will find IPC-1752B based notifications to the SCIP database from every industry sector. The majority of these SCIP notifications, over 1.4 million notifications (74%), have been made by companies supplying mechanical products. Suppliers in the automotive industry have used IPC-1752B to prepare and submit over 420,000 SCIP notifications (22%) and suppliers in the aerospace industry have used IPC-1752B to prepare and submit over 82,000 SCIP notifications (6%). Any company in any industry sector can use IPC1752B to exchange information with their supply chains in a format which matches the data requirements of the ECHA SCIP database. Additionally, IPC-1752B based notifications to the SCIP database have been made from companies in every EU Member State in Europe. Companies in every one of the 27 EU Member States have used the IPC-1752B standard to collect supplier declarations and prepare SCIP notifications.

You can learn more about Proactive Alliance here. 


 

IPC Standards as Compliance Tools
Utilizing IPC-1754Am2 Materials and Substances Declarations for SCIP Compliance

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. 

IPC-175x Solution Provider Review

IPC-1752 Verified Solution Providers

The IPC-1752 Materials Declaration Standard Verified Solution Providers List


IPC-175x Solution Provider Review

IPC-1754 Verified Solution Providers

The IPC-1754 Materials and Substances Declaration for Aerospace and Defense and Other Industries Standard Verified Solution Providers List