The European Chemicals Agency (ECHA) was established to ensure chemicals that enter the EU market are safely used. It implements the chemical legislation of the EU, which has direct benefits on human health and the environment. The agency has established initiatives such as the Substances of Concern in Products (SCIP) and Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) for promoting and regulating the safe use of chemicals.
REACH Requirements vs SCIP Reporting Obligations
Both REACH SCIP initiatives mainly differ in their data requirements. The SCIP databases’ data requirements are more complex than the requirements of the REACH directive. Also, they require significant amounts of information from a company’s supply chain. The database requires article declarations at each stage of the manufacturing process. The SCIP database contains substances on the REACH SVHC list, although the required information covers bigger grounds like material identification, HTS codes, article number, and the number of components. Products that are in the scope of REACH are also impacted by SCIP. However, the data collected for REACH compliance is not enough to meet the database standards of ECHA.
Understanding the SCIP Database
The SCIP database is meant to offer waste operators information on hazardous substances contained in the waste they process. This way, they can recycle the materials and reuse them to produce new articles. Articles suppliers should submit the information that permits the identification of the article, the SVHC name, location, and concentration range, as well as other data on the safe utilisation of the article to the SCIP database.
Companies in Scope
The SCIP database requirements affect nearly all manufacturers or sellers of products that contain SVHCs above the set threshold in Europe. EU producers and assemblers, importers, and article distributors must give information to ECHA. When it comes to non-EU sellers, the first recorded importer will have to fulfill the SCIP database reporting obligations. To fulfill such requirements, importers must obtain supply chain data from non-EU partners.
Exemptions may be available to companies that manufacture articles utilised for national defense or security. Distributors that fail to change an article or product with a valid SCIP dossier from an importer or manufacturer don’t have to report. This requirement does not apply to retailers that directly sell to consumers.
Companies that need to meet the SCIP database requirements should consult with experts who can help them register products with the database. These experts can give them advice on the compliance process, preparing their notification dossier for submission, and necessary testing.