SCIP & SVHC Compliance

SCIP Database and SVHC Compliance under EU REACH

🧾 Introduction
Substances of Very High Concern (SVHCs) are central to the European Union’s Regulation (EC) No 1907/2006 on the Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH).

Every manufacturer, importer, and distributor placing products on the EU market must determine whether an SVHC above 0.1 % (w/w) is present and ensure that all relevant information is properly communicated and submitted to the European Chemicals Agency (ECHA) SCIP database.

This article explains the relationship between REACH Article 33 communication duties and the SCIP database, along with examples of digital dossier creation and submission workflows.

The development of the SVHC Candidate List begins with a proposal by an EU Member State or the European Commission.

Key stages include:

• Public consultation and peer review.
• Establishment of the Candidate List and subsequent updates.
• Prioritization of high‑risk substances for inclusion in Annex XIV.
• Continuous communication with customers and notification to ECHA.

Companies must evaluate each article to confirm if an SVHC listed under Article 57 and 59 (1) is present at concentrations exceeding 0.1 % by weight.

📜 Article 33 Compliance Obligations

Article 33 imposes two major communication requirements:

B2B Communication:
Suppliers must provide professional recipients with sufficient information for safe use, including at minimum the substance name.

Consumer Information:
Upon request, suppliers must provide equivalent details within 45 days, free of charge.

Transparency may be achieved by including this information on company websites, standardized REACH letters, or through existing databases such as IMDS.

The Court of Justice of the EU ruled that the 0.1 % threshold applies per individual component article, not across an entire finished product.

This principle—“once an article – always an article”—means that if any component (for example, a bicycle tyre, handlebar grip, or soldered joint) contains an SVHC above 0.1 % by weight, suppliers must communicate that information accordingly.

🧩 The SCIP Database and Its Purpose

Under the Waste Framework Directive, the SCIP regulation obliges suppliers to report any article containing SVHCs listed on the ECHA Candidate List above 0.1 %.

The objectives are to:

• Improve visibility of hazardous substances throughout a product’s lifecycle.
• Assist waste operators in handling materials safely.
• Support recycling, substitution, and waste‑prevention goals within the circular economy.

Minimum information required for a basic article:

• Primary identifier
• Article name 
• HS code 
• Safe‑use instructions
• Material category
• Candidate‑list substance
• Concentration range

Complex articles must also describe the presence and location of SVHC‑bearing components.

ECHA allows grouping to simplify notifications:
- Identical articles with the same composition and purpose.
- Semi‑identical articles with the same SVHC and mixture categories.
- Quasi‑identical articles that differ only in colour or dimensions.

Each group can be reported under a single Primary Article Identifier, such as sets of smartphones or O‑rings sharing identical material characteristics.

💻 SCIP Information Flow and Submission Options

SCIP notifications can be prepared and delivered using several methods:

1. Portal‑based submission: Build dossiers directly within ECHA’s web interface.

2. Cloud submission: Upload IUCLID (.i6z) files securely via ECHA Cloud Services.

3. System‑to‑System (S2S) submission: Automated data exchange that enables synchronized dossier creation and submission from in‑house compliance systems.

Data collected from companies (duty holders) is validated by ECHA, stored in the central SCIP database, and made accessible to authorized parties such as waste operators and consumers.

Distributors can fulfil obligations through Simplified SCIP Notification (SSN), referencing the supplier’s previously submitted SCIP number.

This avoids creating separate dossiers, provided the article delivered is identical to the one received.

Referencing also allows linkage between complex‑object dossiers—for instance, connecting a PCB assembly containing lead solder to a higher‑level product structure—reducing duplication and maintaining full traceability.

⚙️ Technical Dossier Creation and Automation

Automated systems enable dynamic XML generation for SCIP dossier files (.i6z), where article and substance information is structured using PHP arrays.

Loop functions iterate through each substance, populate unique UUIDs, embed XML nodes for Candidate List Substance Link, Concentration Range, and Material Categories, and assemble manifests summarizing folder contents.

This approach increases flexibility compared with static templates and ensures compatibility with ECHA’s IUCLID format. Once compiled, the dossiers are submitted automatically using a submitS2S function, completing the regulatory submission workflow.

🤝 How ComplyMarket Supports Organizations

Achieving seamless compliance with REACH Article 33 and the SCIP database requires more than documentation—it demands cross‑functional expertise in chemical management, digital systems, and regulatory interpretation.

ComplyMarket supports manufacturers, importers, and distributors by:
- Advising on identification and communication of SVHCs above 0.1 % (w/w).
- Implementing automated workflows for dossier creation and S2S transmission.
- Verifying data integrity, UUID linkages, and XML file compliance.
- Guiding on grouping, referencing, and Simplified SCIP Notifications (SSN).
- Providing training and up‑to‑date insights on evolving ECHA regulations.

With professional support, businesses can maintain confident market access, minimize administrative risk, and ensure lasting compliance in the evolving European regulatory landscape — all supported by ComplyMarket.