Here’s everything you need to know about the origin of the SCIP database and if you are affected by this new requirement.
What is the SCIP database?
The Waste Framework Directive (2008/98/EC) from Nov/2008 establishes the legislative framework for the generation, handling and management of waste on the environment and human health. The main goal of the framework is to ensure a harmonized, safe and secure management of industrialized material waste and promote efficient use of resources.
As part of the revised Waste Framework Directive entered into force in July 2018, ECHA develops a database to manage information on articles containing substances of very high concern (SVHCs). This is called the SCIP Database (Substances of Concern In articles as such or in complex objects (Products)).
The SCIP database gathers all collected information together and aims to improve transparency on hazardous substances in articles to the end consumer, authorities and waste operators. It ensures that relevant information is available throughout the whole lifecycle of products and materials, also at the waste stage.
Am I affected?
All companies producing, importing or supplying articles into the EU market must check whether their articles need to be reported to the SCIP database.
What needs to be notified?
Articles and complex objects placed on the EU market that contain SVHCs in a concentration above 0.1% w/w (weight by weight).
“SVHC “ or “Candidate List” refers to the Candidate List of substances of very high concern for Authorisation according to Article 59(10) of the REACH Regulation. These substances have potential risks for human health and the environment.
Here’s an overview of terminology used in SCIP:
- Complex Object – an object that is made up of two or more articles. In other words, several articles can be joined together to create a complex object. For example, a bicycle.
- Articles – an object that cannot be dismantled into parts. Articles keep their shape, surface or design. But, they can contain several materials. For example, the bicycle frame or the saddle.
- SVHC (substances of very high concern) – substances with hazardous properties. Namely, classified as carcinogenic, mutagenic or toxic for reproduction (CMR), or persistent, bio-accumulative and toxic (PBT) and very bio-accumulative (vPvB)m, or on a case-by-case basis that cause equivalent levels of concern as CMR or PBT/vPvB substances.
What data is required?
Companies that are affected by the directive, must submit the following information to the database:
- Information to allow the identification of the article such as name, primary identifier, etc.
- Information on the concern element, i.e. the Candidate List substance that is present in the article, such as substance identification, concentration range, material or mixture category, etc.
- Information on safe use of the article, including information on proper management at the waste stage
This documents with the snapshot of information is collected into an i6z file, or for a less technical term, a dossier, that is submitted to the SCIP Database. Once submitted, you will receive a UUID for that dossier.
When must I submit data?
5th January 2021
What steps should I take to submit a dossier to the SCIP database?
We get asked this question a lot. While we can help you with the IT side of things such as generating dossiers in the correct format and setting up an automated system to ensure that dossiers get submitted and updated, you should start with the following:
- Collect data about your products. You may have to reach out to your suppliers and manufacturers to get this information.
- Evaluate the data and check how many of your products are affected, i.e., contain SVHCs.
- Analyze if you need IT system support. If you only have a handful of affected products, you might choose to manually submit a SCIP dossier using the ECHA cloud. However, if these products are updated or changed frequently, an IT system would be efficient to catch these changes and ensure that you update your SCIP dossier accordingly.
Feel free to reach out to us to learn more about implementing an IT system to fulfill your SCIP obligations. Contact us.
Is preparing a SCIP dossier for the SCIP database complex?
At opesus, we have been following any updates and changes to the SCIP database requirements diligently. We are part of the ECHA SCIP IT User Group for the SCIP database, which allows us to react quickly to the various revisions. For example, if there is a change in the validation rules, we adjust our solution accordingly. In this way, the dossiers that you generate in your system will be checked against the latest validation rules before they are submitted to the SCIP Database.
This is why we believe that without a properly set-up IT system, it will be a challenge for companies to keep up with regulatory changes and product changes simultaneously. Let us help you! Contact us.