SCIP Database (WFD) Compliance: Submission & Updates

📌 What the law requires (WFD + REACH Article 33)

The legal basis is the revised EU Waste Framework Directive (Directive (EU) 2018/851 amending Directive 2008/98/EC). It requires Member States to ensure that any supplier of an article provides to ECHA the information pursuant to REACH Article 33(1) as from 5 January 2021.

In practice, SCIP makes REACH Article 33(1) information submit-to-ECHA, not only “provide-to-recipient on request.”

✅ Who must submit a SCIP notification

You are typically in scope if you place articles on the EU market as an EU-based:

• 🏭 Producer (article producer) or 🚢 Importer
• 🧩 Assembler placing complex objects on the market
• 📦 Distributor or other supply-chain actor placing articles on the market

A common exclusion referenced in practice: retailers/actors supplying directly and exclusively to consumers (where they are not also producers/importers).

🔍 When SCIP reporting is triggered

A SCIP notification is required when an article (as such or within a complex object) contains a Candidate List SVHC above 0.1% weight by weight (w/w).

Key operational point: reporting is triggered for each component article exceeding the 0.1% threshold (“once an article, always an article”).

🧾 What you must submit (SCIP information requirements)

At a minimum, duty holders must submit:

• 🏷️ Identification of the article
• 🧪 Name of the Candidate List substance, plus concentration range and location in the article/complex object
• 🛡️ Safe use / waste-management information, notably what supports proper handling once the article becomes waste

🧩 Data you need to have “SCIP-ready” (practical field checklist)

1) Article identification (make items uniquely matchable)

• Article name (clear, consistent naming)
• Primary article identifier (e.g., EAN/GTIN, catalogue/part number)
• Optional additional identifiers (brand, model, internal code)

2) Article category (classification)

• CN/TARIC code used as the article category for SCIP classification

3) SVHC (concern element) details

• Candidate List substance identity (e.g., CAS/EC identifiers)
• Concentration range selection (range-based, not necessarily exact %)
• Material category (and optional extra material characteristics)

4) Complex object structure (location matters)

• A component hierarchy that shows where the SVHC-containing article sits inside the supplied product (and how many units, when relevant).

5) Safe use & disassembly/waste instructions (when needed)

• Short, product-appropriate guidance for normal use and end-of-life handling (and disassembly steps where relevant).

🛠️ How to submit (tools + channel)

You prepare SCIP notifications in the harmonised IUCLID format, then submit through the ECHA Submission Portal.

Preparation options used by companies include:

• ☁️ IUCLID Cloud (online)
• 💻 IUCLID 6 Desktop/Server (offline)
• 🔄 System-to-system submission (API-based interfaces from your IT systems to the portal)

🔁 How to reduce workload (SSN + Referencing)

ECHA’s simplification mechanisms (voluntary) are designed to prevent duplicate reporting:

• Simplified SCIP Notification (SSN): if the article is not changed, you can refer to a supplier’s successfully submitted data without preparing a full dossier (useful for distributors and group structures).
• Referencing: if a notified article is incorporated into a complex object, you can reference the existing component notification instead of re-entering the same dataset.

🔔 Ongoing compliance (updates and change control)

SCIP is not “submit once and forget.” You need a process to detect and act on changes such as:

• New SVHC additions to the Candidate List (commonly updated twice per year)
• BOM/component changes that affect SVHC presence, concentration range, material category, or location mapping
• Identifier or classification changes (part numbers, CN/TARIC) that impact traceability

🧠 What your company should do to comply

1) Scope your portfolio

• List all EU-placed articles and complex objects (including spares) by part number/SKU.
• Identify which items can reuse supplier data (SSN/Referencing candidates).

2) Build the data backbone

• Create a consistent article → component → material/mixture → SVHC structure.
• Standardise naming rules and primary identifiers to avoid duplicates.

3) Collect supplier declarations at the right level

• Require SVHC disclosures per component article (not generic “REACH compliant” statements).
• Capture: SVHC identity, concentration range inputs, material category, and location in the product.

4) Prepare dossiers and validate

• Populate mandatory fields, check CN/TARIC coding, ensure SVHC location is unambiguous, and add safe use/waste instructions where needed.

5) Submit and retain evidence

• Keep submission receipts, dataset versions, supplier evidence, and internal approvals in a controlled record.

6) Run updates as a standard process

• Link Candidate List updates + engineering change orders to automatic “SCIP impact” review and resubmission decisions.

⚠️ Common pitfalls to avoid

• Treating 0.1% as a “whole product average” instead of a component article threshold.
• Missing SVHC location inside complex objects (no usable hierarchy).
• Inconsistent part identifiers (duplicate submissions, broken traceability).
• No update triggers tied to BOM and supplier changes.

⭐ Why ComplyMarket is the best solution for SCIP Database (WFD) compliance

ComplyMarket turns SCIP into a controlled, scalable process by combining material compliance management, product structure governance, and submission-ready reporting in one platform.

With ComplyMarket, companies can:

• 🧩 Maintain complex object hierarchies that reliably capture SVHC location for SCIP.
• 🧪 Centralise Candidate List intelligence and link it directly to parts, materials, and suppliers.
• 🧾 Generate IUCLID-ready SCIP datasets with consistent identifiers, CN/TARIC logic, concern elements (concentration ranges + material categories), and safe-use/disassembly statements.
• 🔁 Support workload reduction with workflows aligned to SSN/Referencing operating models.
• 📌 Keep strong traceability: what changed, who changed it, which products are impacted, and what was submitted—so SCIP stays compliant as products and regulations evolve.