In 2018 the Substances of Concern In Articles, as such or in complex objects (Products) (SCIP) database was announced. Mandated under the EU Waste Framework Directive (EU) 2018/851, companies doing business in the EU — whether selling or importing into or manufacturing within the EU area — are required to submit information to the database when articles in their products contain substances of very high concern (SVHCs).
As of August 1, 2022, SCIP database reporting requirements were extended to the entire European Economic Area (EEA), which includes the 27 EU member states as well as the European Free Trade Association (EFTA) states Iceland, Norway, and Liechtenstein. As of November 7, 2022, EFTA states are able to submit notifications to the SCIP database; before this date, the database was not equipped to accept these submissions.
Get an in-depth analysis of your SCIP database reporting requirements in our SCIP Database Handbook: Your Guide to Compliance.
What Are the SCIP Reporting Requirements
First, a review of the SCIP database reporting requirements. Enforced by the European Chemicals Agency (ECHA), in-scope companies must create an ECHA SCIP-IT account; submit company, product, article, and substance information; and maintain the accuracy of dossiers as ECHA expands the SVHC Candidate List or as company/product information changes.
Companies in scope must submit dossiers for each article within a product containing an SVHC. This means that products containing numerous parts (or articles in EU materials compliance vernacular) must submit multiple dossiers (one for each article) even if a manufacturer considers its product a single item.
For example, if a computer contains thousands of parts/articles, an in-scope manufacturer of a motherboard would be required to submit (or reference) a SCIP dossier for the motherboard itself, the board’s RAM slots, and the screws holding the RAM slots attached to the motherboard. Even that example only examines the RAM component of a motherboard. This theoretical manufacturer could be required to submit dossiers for every attached component of the motherboard, potentially hundreds of dossiers for a single product.
What EEA Countries Should Expect
The SCIP database was officially launched on January 5, 2021. In the following months, the database received millions of submissions, many of which were flawed — potentially making hundreds of companies non-compliant with their requirements. Submissions that were correct often took hundreds of hours to compile and validate.
Thankfully, for companies in Iceland, Norway, and Lichtenstein, our understanding of SCIP requirements and how to meet them has improved dramatically. A month after launch, ECHA issued a press release warning in-scope companies that incomplete or unacceptable SCIP submissions weren’t compliant with EU Waste Framework Directive requirements. They advised:
- Collaborating within the supply chain to streamline data collection efforts
- Breaking down complicated product hierarchies (of over 1,000 components)
- And “referencing” complex dossiers
“Referencing” is a practice wherein a manufacturer connects to a supplier’s unique SCIP Dossier ID to meet their requirements. In the above motherboard example, the company would “reference” the SCIP ID of the RAM slot manufacturer if that company submitted it to the SCIP database. In November 2022, ECHA also improved the SCIP database to accept submissions from the EFTA states.
The EEA countries can lean on the expertise of companies — such as Assent — that have been helping manufacturers submit to the database since its launch. This familiarity with the requirements allows newly in-scope manufacturers to meet ECHA’s suggestions and target data management efforts to be more effective.
System-to-System Transfers
To be accepted, dossiers must meet IUCLID formatting standards. Companies can submit to the SCIP database in three ways:
- Offline, using internal IT services
- Online, using ECHA Cloud services
- Through a direct system-to-system (S2S) transfer
S2S transfers are the preferred method for many companies. By partnering with Assent, manufacturers have submitted thousands of dossiers directly to ECHA using Assent’s system-to-system capabilities.
Assent’s SCIP Solution
Assent works with over 600 complex manufacturers to manage supply chain sustainability requirements, including SCIP database reporting. Purpose-built for manufacturers with complex products, Assent’s solution was developed in partnership with experts intimately familiar with the ECHA-IT requirements. Using the Assent platform, companies can manage SCIP requirements from beginning to end in one solution, reducing the time and money required for compliance and mitigating the significant risk of human error.
To learn more about Assent’s SCIP solution, contact us at info@assent.com.
