Question 1

What is the SCIP database?

Accepted Answer

The SCIP database (Substances of Concern In articles as such or in complex objects (Products)) is managed by the European Chemicals Agency (ECHA) under the EU Waste Framework Directive. It requires companies to report articles containing substances of very high concern (SVHCs) above 0.1% w/w. The ECHA SCIP database helps waste operators, consumers, and regulators improve safe disposal, recycling, and substitution of hazardous substances.

Question 2

What is SCIP compliance and who must comply?

Accepted Answer

SCIP compliance means meeting the EU Waste Framework Directive requirements to submit product data into the ECHA SCIP database. Companies that manufacture, assemble, import, or distribute articles in the EU containing SVHCs above the 0.1% w/w threshold are responsible for submissions. Retailers selling directly to end consumers are exempt. Non-EU companies are not legally bound but must provide accurate product data to their EU partners to maintain access to the EU SCIP database.

Question 3

How do SCIP database submissions differ from EU REACH reporting requirements?

Accepted Answer

While both SCIP and EU REACH Regulation track substances of very high concern (SVHCs), the SCIP database EU requirements are more detailed. SCIP submissions must include article-level identifiers, SVHC concentration ranges, material categories, and safe use information. By contrast, REACH reporting focuses on supply chain communication, while the ECHA SCIP database is designed to support end-of-life (EOL) disposal and waste treatment.

Question 4

What data is required in a SCIP database submission?

Accepted Answer

A SCIP database submission must include several mandatory fields, including:

Identifying information about the article (name, category, unique identifiers)
Candidate List SVHC data, including concentration range and reference substance file
Safe use instructions for waste operators, industrial users, or consumers
Material categories (e.g., metals, plastics, glass) to support recycling and risk management

There are also over a dozen optional fields that are considered best practice to include.

Submissions can be made through the ECHA IUCLID software (online or offline) or by using a third-party SCIP compliance platform.

Question 5

What is the EU Waste Framework Directive and how does it relate to the SCIP database?

Accepted Answer

The EU Waste Framework Directive (WFD) sets out rules to protect human health and the environment from risks linked to waste. Updated in 2018, it requires the creation of the SCIP database system, where companies must report articles containing SVHCs above 0.1% w/w. The European WFD ensures hazardous substances are traceable throughout the product lifecycle, from production to waste management, creating greater transparency and supporting the EU’s circular economy goals.

Question 6

What are EPR packaging laws, and why do they matter for manufacturers?

Accepted Answer

Extended producer responsibility (EPR) packaging laws make manufacturers financially and operationally responsible for managing their packaging waste at the end of its life. Under these laws, producers must fund recycling, reporting, and waste management programs through Producer Responsibility Organizations (PROs).In the U.S., EPR is state-driven, meaning compliance varies by state. Manufacturers must track packaging data, report to the appropriate PRO, and pay eco-modulated fees based on recyclability and material composition.EPR laws support a circular economy, reduce landfill waste, and help manufacturers meet sustainability goals.

Question 7

How do manufacturers comply with EPR packaging requirements?

Accepted Answer

Compliance typically involves four key steps:Register and join the appropriate Producer Responsibility Organization (PRO).Track and report the types, weights, and recyclability of packaging materials placed on the market.Pay PRO fees, which may vary based on packaging recyclability (eco-modulation).Meet recycling and content targets — for example, post-consumer recycled content in plastics and paper.Manufacturers must also monitor updates to avoid gaps in compliance across states. Using centralized EPR compliance software helps automate reporting and ensures data accuracy across jurisdictions.

Question 8

How can manufacturers prepare for EPR compliance and avoid penalties?

Accepted Answer

The best way to avoid EPR compliance risks is through proactive preparation and consistent data management. Start by identifying where your products are sold, what materials your packaging uses, and whether those materials are in scope for EPR programs. From there, establish internal tracking processes and join a Producer Responsibility Organization (PRO) early.Manufacturers can also reduce costs and risk by designing recyclable or reusable packaging, centralizing reporting data, and automating updates across states as new regulations emerge. Investing in an EPR compliance platform helps ensure you meet reporting deadlines, maintain audit-ready documentation, and stay ahead of rapidly changing state requirements.

Question 9

How does Assent help manufacturers manage EPR packaging compliance?

Accepted Answer

Assent helps manufacturers simplify and scale their EPR compliance across multiple U.S. states. The Assent Sustainability Platform centralizes packaging data, automates reporting to Producer Responsibility Organizations (PROs), and keeps you ahead of evolving requirements.With Assent, you can track material composition, calculate packaging weights, and generate audit-ready reports that align with state-specific EPR laws, from California’s SB 54 to Colorado’s HB 22-1355. The platform also provides real-time regulatory updates, so you’re never caught off guard by new reporting deadlines or scope changes.

Question 10

What is the BIS 50% Rule (Affiliates Rule)?

Accepted Answer

The BIS 50% Rule is a new U.S. export control requirement that extends Entity List and MEU List restrictions to any company that is 50% or more owned (directly or indirectly) by one or more listed entities. This includes subsidiaries, holding companies, offshore structures, and multi-layer corporate ownership.

Question 11

When will the BIS 50% Rule be fully enforced?

Accepted Answer

The rule becomes fully enforceable in November 2026, but early preparation is essential due to the difficulty of uncovering hidden ownership relationships.

Question 12

What are the risks of BIS 50% Rule non-compliance?

Accepted Answer

Organizations face export privilege loss, regulatory penalties, and significant shipment delays. Many companies now search for BIS 50% Rule penalties and export control enforcement as enforcement tightens.

Question 13

How does Assent support BIS 50% Rule compliance?

Accepted Answer

Assent’s Enhanced Entity Screening integrates AI-powered analysis, ownership tracing, and expert review to:Identify complex indirect ownership chainsUncover offshore or layered affiliatesConsolidate beneficial ownership data across jurisdictionsApply OFAC and BIS style 50% ownership logicProduce defensible evidence for audits and licensing decisions

Question 14

What are Persistent Organic Pollutants (POPs)?

Accepted Answer

Persistent organic pollutants (POPs) are toxic chemical substances that resist natural breakdown, remain in the environment for long periods, and build up in living organisms. Examples include polychlorinated biphenyls (PCBs), DDT, and dioxins. POPs can travel long distances through air and water, affecting ecosystems and human health worldwide.

Question 15

What is the EU POPs Regulation (EU 2019/1021)?

Accepted Answer

The EU POPs Regulation, also known as Regulation (EU) 2019/1021, is the European Union’s legal framework for controlling persistent organic pollutants. It enforces the Stockholm Convention by restricting or banning POPs production, use, and disposal to prevent environmental contamination.

Question 16

Which industries are most affected by POPs legislation?

Accepted Answer

Industries such as electronics, automotive, textiles, and construction are most affected by persistent organic pollutant (POP) regulations. These sectors often use materials containing POPs, such as flame retardants, lubricants, or plasticizers, and must comply with EU POPs restrictions to continue selling products in the European Union.

Question 17

How can companies ensure compliance with the EU POPs Regulation?

Accepted Answer

To comply with the EU POPs Regulation, companies should collect full material disclosures (FMDs) from suppliers, perform chemical screening to detect POPs, and use Persistent Organic Pollutants (POPs) Compliance software. Ongoing monitoring of new POPs listings under the Stockholm Convention helps maintain compliance as regulations evolve.

Question 18

What is the EU Waste Framework Directive and why does the SCIP database matter for manufacturers?

Accepted Answer

The EU Waste Framework Directive (WFD) is a cornerstone of the European Union’s circular economy strategy, requiring manufacturers to design products for durability, reuse, and waste reduction. A key update in 2018 introduced the SCIP database, the Substances of Concern In articles as such or in complex objects (Products) database,  managed by the European Chemicals Agency (ECHA). Manufacturers, importers, and assemblers must report products containing Substances of Very High Concern (SVHCs) above 0.1% weight-by-weight (w/w) to the SCIP database. This improves supply chain transparency and supports safe recycling and waste handling.

Question 19

Who must submit data to the SCIP database under the Waste Framework Directive?

Accepted Answer

Any company that manufactures, assembles, imports, or distributes products in the EU market containing SVHCs above 0.1% (w/w) must make a SCIP submission.EU-based companies, including first importers have direct legal responsibility.Non-EU suppliers must provide data to their EU partners to maintain market access.The only exception is retailers selling directly and exclusively to end consumers. To determine if you’re in scope, review your supply chain data against the REACH Candidate List, which is updated about every six months.

Question 20

How does SCIP reporting differ from REACH compliance?

Accepted Answer

While both REACH and SCIP address hazardous substances, SCIP goes deeper.REACH focuses on the registration and restriction of chemicals.SCIP requires a granular declaration of SVHCs at the article level, including details like material category, safe use information, and concentration ranges. In short, REACH manages chemicals, while SCIP manages transparency, ensuring every product component containing an SVHC can be identified and safely handled at the end of its life cycle.

Question 21

How can manufacturers efficiently meet SCIP database requirements?

Accepted Answer

Compliance begins with accurate data collection and supplier collaboration. Manufacturers should:Map all products and identify SVHCs.Collect detailed article- and material-level data following ECHA’s IUCLID format.Use a compliance management solution to automate submissions and maintain accuracy.Solutions like Assent’s SCIP compliance software centralize supplier data, track REACH Candidate List updates, and simplify dossier submissions, helping companies shift from reactive compliance to proactive risk management.