REACH SVHC: DON'T SKIP SCIP

What is the REACH SCIP?

The ECHA (European Chemicals Agency) has built the SCIP online database to improve the REACH SVHC (Substances of Very High Concern) reporting transparency, for most products placed into the European Union (EU) market.

SCIP stands for Substances of Concern In Products. The long official version is Substances of Concern In articles, as such, or in complex objects (Products).

Here is the current public SCIP database.

The SCIP database declaration:

enables greater transparency on the presence of SVHCs above the threshold in products;
influences purchasing choices, and;
enhances waste reduction, treatment, and recycling through the product life cycle and circular economy. These two approaches follow the EU Waste Framework Directive (WFD) and the European action plan for a circular economy.

The SCIP Implementation

Here is the timeframe of the SCIP database implementation:

Autumn 2019: launch of a user test group and a stakeholder workshop;
Early 2020: launch of the prototype version of the database;
July 2020: deadline for Member States to transpose the SCIP requirements into their national laws;
October 2020: it is possible to enter REACH data into the SCIP database;
January 5th, 2021: SCIP online notification becomes mandatory.

Why does the REACH SCIP Reporting Matters?

Depending on your supply chain, the SCIP declarations apply to importers, assemblers, distributors, or manufacturers of articles. If you are a manufacturer offering your products to the European market, chances are that you are directly impacted by the SCIP reporting.

In essence, if after January 5th, 2021:

You don’t declare anything on the SCIP database, then you are stating that your products don’t contain any SVHCs above the threshold.

You find out SVHCs listed in the Candidate list in your products above the 0.1% threshold, then you must declare these SVHCs on the SCIP database accordingly.

Requested SVHC Information under the REACH SCIP

Details on the SCIP Notification of SVHCs

The SCIP requires a high level of detail on products containing SVHC(s). Product information in the SCIP database notification includes:

The name of the articles (like components in your product) containing at least one SVHC above the declaration threshold;
The category of the articles and materials containing SVHC(s);
Safe use instructions;
SVHC names and the CAS numbers(s) when available;
The European Article Number (EAN).

Since the REACH SVHC list is updated every six months, the SCIP declarations must be updated accordingly if any new SVHC is present in the product above the 0.1% threshold, following the ‘once an article, always an article ‘ rule.

REACH SVHC Reporting: What Changes and What Remains the Same

The following table portrays the evolution of the SVHC notification and the additional requirements :

Before 2021	As of 2021, with the SCIP Database Notification
Inform users of all the SVHCs contained in your product (name and CAS #)	Same
Provide safe use information of your product, considering the declarable SVHC	Same
–	Enter what components contain SVHC in your product
–	Provide safe use information of every component containing SVHC in your product
–	Give the article category of every component containing SVHC in your product
–	Give every material category containing SVHC in the impacted components of your product

Useful SCIP Compliance Tools

A SCIP database is available online. You need to create an account to access ECHA Cloud Services, including the SCIP database.

ECHA also offers insightful REACH support and workshops on SCIP, including guidance on how to prepare and submit a SCIP notification dossier.

You can use the free Enviropass Product Environmental Compliance (ECEP) form, REACH tab, to gather the necessary REACH information per component.

The IPC Association Connecting Electronics Industries has also created the standard IPC-1752B to enhance REACH reporting.

Enviropass:

contacts your suppliers;
verifies the gathered REACH information, and;
takes care of your SCIP notifications.

Ask for a free online consultation and see how!

Should you have any questions on the REACH SCIP notification of SVHC, don’t hesitate to contact Enviropass.

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