EU SCIP Notification Requirements

Overview of SCIP Notification

As part of the European Union's move toward a safer and more sustainable circular economy, companies placing products on the EU market must now provide detailed information regarding hazardous substances. This is mandated through the SCIP notification, a key requirement established under the revised Waste Framework Directive (WFD 2008/98/EC).

The term SCIP stands for "Substances of Concern In articles as such or in complex objects (Products)". It requires companies to submit information to the European Chemicals Agency (ECHA) regarding articles containing Substances of Very High Concern (SVHC) on the Candidate List in a concentration above 0.1% weight by weight (w/w). Since January 5, 2021, all companies circulating such products within the EU must fulfill this submission obligation. The information is stored in the SCIP database, a platform accessible to waste operators and consumers to ensure transparency and safety throughout the entire product lifecycle.

Proregulations offers comprehensive support to help enterprises navigate these transparency mandates and ensure their products remain compliant with current EU environmental standards.

Importance of the SCIP Database

The establishment of the SCIP database serves several critical environmental and industrial objectives within the EU.

• Improving knowledge about hazardous chemicals in products throughout their entire lifecycle.
• Encouraging the substitution of hazardous chemicals with safer alternatives.
• Managing hazardous substances in waste streams during the collection and recycling phases to promote a cleaner circular economy.
• Supporting the reuse and recycling of materials by providing clear data to waste operators.

Entities Subject to Notification Duties

The obligation to submit a SCIP notification applies to various actors within the EU supply chain:

• EU manufacturers and assemblers.
• EU importers.
• EU distributors and other actors who place articles on the market.

It is important to note that retailers who supply products exclusively to consumers and waste disposal operators are not required to submit SCIP notifications. However, non-EU companies can provide technical support through designated third-party providers to help their EU-based partners fulfill these requirements.

Mandatory Information for Submission

A valid SCIP notification must contain specific data points to ensure the accurate identification and tracking of hazardous substances:

• Article Identification: Details such as name, identification numbers, and article category (based on the Integrated Tariff of the European Communities or TARIC list).
• SVHC Details: Specifically the name, CAS number, and concentration range of the substance.
• Safe Use Instructions: Guidance for users and waste operators on how to handle the article safely.

Notification Timeline and Process

For products placed on the market before January 5, 2021, the notification obligation began on that date. For products produced or imported after this date, the notification must be submitted before the product is first placed on the EU market.

The notification process involves several technical steps:

1. Data Collection: Gathering necessary information via IUCLID (online or offline).
2. Submission Method: Uploading data through the ECHA submission portal or integrating with internal IT systems using System-to-System (S2S) methods.
3. Receipt of Report: Confirming the submission and reviewing the comprehensive report status.

Proregulations' SCIP Compliance Support Services

Managing complex supply chain data for SCIP notifications requires specialized expertise in chemical regulations and data management. Proregulations provides comprehensive support to streamline this process.

• Third-party representative services
  We assist non-EU enterprises in coordinating with their EU partners to ensure accurate data transfer and compliance.
• SVHC compliance solutions
  Our team helps identify SVHCs in articles and manages the entire process from identification to final notification.
• Threshold and condition evaluation
  We assess whether your products trigger the SCIP notification requirements based on concentration and material composition.
• SCIP notification services
  Proregulations manages data preparation, dossier creation in IUCLID, and formal submission to ECHA.
• Regulatory training and consulting
  We offer customized workshops and advisory services to help your internal teams build the capability to manage SCIP requirements independently.

If you need to ensure your articles are fully compliant with the latest EU SCIP notification mandates and environmental standards, please contact us.