UPDATE: SCIP Database Requirements May Apply to Your Company
Earlier in November, the European Chemicals Agency clarified the date from which information should be communicated to ECHA via the SCIP database. According to this support site, information on articles containing SVHCs on the Candidate List in a concentration above 0.1% w/w placed on the EU market needs to be notified to ECHA from January 5, 2021 onwards. They state that Member States should ensure national rules are in place to oblige all suppliers to provide information to ECHA “as from” January 5, 2021 and not “as of” January 5, 2021.
Key Summary
• ECHA clarified that SCIP notifications must be submitted for applicable articles placed on the EU market starting January 5, 2021
• Companies must report articles containing SVHCs above 0.1 percent to the SCIP database
• The timeline remains tight despite industry requests for an impact assessment
• IPC continues advocating for a more workable approach and urges companies to prepare
• ECHA offers tools and a webinar to help organizations meet reporting obligations
On October 28, the European Chemicals Agency (ECHA) formally launched the Substances of Concern in Products (SCIP) database. Any company importing, producing, or supplying products on the EU market that contain substances of very high concern will have to comply with the database reporting requirements. Specifically, if your company places on the market any articles with SVHCs on the REACH Candidate List above 0.1% weight by weight then the company must submit information on these articles to the SCIP database as of January 5, 2021.
Despite urgings from IPC and other associations, the European Commission rejected the possibility of an ex-post impact assessment. Under the current timeline, the regulatory obligations regarding the database are set to come into effect on January 5, 2021, just 10 weeks after the database was unveiled for the first time. However, industry advocacy will continue, and IPC recently signed a cross-industry letter to the German Presidency of the European Union and heads of the European Council and European Parliament, reiterating the need for a more workable solution. IPC will continue advocacy efforts and stresses the need for companies to increase their awareness about this regulatory requirement.
ECHA has tools available to help you to meet reporting obligations and be sure to tune into the ECHA’s November 19 webinar if you have any questions about the notification process, and let us know if we can help you.
ECHA clarified that Member States should require suppliers to submit notifications “as from” January 5, 2021, meaning all articles with SVHCs placed on the market from that date onward must be reported to the SCIP database.
Any company importing, producing, or supplying articles in the EU that contain substances of very high concern above 0.1 percent weight by weight must submit information to the SCIP database beginning January 5, 2022
The database launched only 10 weeks before reporting obligations began. Companies must quickly understand requirements, gather data, and prepare submissions, despite limited time and concerns raised by industry groups.
IPC joined a cross-industry letter urging EU leaders to adopt a more workable solution. Advocacy continues to highlight industry challenges and the need for clearer, more manageable compliance pathways.
ECHA provides online tools and guidance to assist with preparing notifications. Companies are also encouraged to attend the November 19 ECHA webinar for information on the submission process and support options.