SCIP

The SCIP database is created under the Waste Framework Directive (WFD) to provide information about Substances of Concern In articles as such or in complex objects (Products).

 

Definitions related to SCIP

Article: Object that is given a specific shape, surface or design during manufacture that determines its function to a greater extent than its chemical composition.

Dangerous Substances: Substances that are considered to have very high concern and are included on the candidate list (SVHC).

Complex Articles: A complex object is composed of multiple products that are either connected or assembled in various ways. In the case of complex objects, the products maintain their status as separate entities as long as they maintain a particular shape, surface, or design.

Article 9 : Prevention of waste

Member States are required to take action to prevent the generation of waste. These measures must, at minimum:

(i) Encourage the reduction of hazardous substances in materials and products, while adhering to harmonized legal requirements for these materials and products that are set at the EU level. Furthermore, it is mandatory that suppliers of articles (as defined in point 33 of Article 3 of Regulation (EC) No 1907/2006 of the European Parliament and of the Council (*)) provide relevant information, as specified in Article 33(1) of the same regulation, to the European Chemicals Agency, beginning from 5 January 2021.

(2) The European Chemicals Agency is responsible for setting up a database to receive data in accordance with point (i) of paragraph 1 by 5 January 2020, and maintaining it. The Agency is obligated to grant waste treatment operators access to the database. Additionally, upon request, the Agency must provide consumers access to this database.

How a directive and a regulation differ

Directive: The regulations shall be obligatory, with respect to the outcome, for every Member State that receives them. However, the form and methods of implementation will be decided by national authorities.

Ex: Waste Framework Directive (WFD)

Regulation: Regulations have legal authority that is binding across all Member States and they come into effect on a specified date in each Member State. Directives, on the other hand, specify particular outcomes that must be accomplished, but Member States have the freedom to choose how they will incorporate the directives into their national legislation.

Ex: REACH

The primary objective of the SCIP database is to enhance understanding of hazardous chemicals present in articles and products throughout their entire life cycle, including the waste phase:

• As of January 5, 2021, businesses that manufacture, assemble, import, or distribute articles containing substances of very high concern (SVHCs) on the candidate list at concentrations above 0.1% (w/w) must provide details about these articles to the EU SCIP database if they are intended for sale on the EU market.
• Retail businesses are not included in the SCIP database regulation unless they also engage in production or importation of articles containing substances of very high concern (SVHCs) on the candidate list at concentrations above 0.1% (w/w).

A comparison of the requirements outlined in REACH Article 33 and the SCIP regulation.

Printed Circuit Board (PCB)

Printed Circuit Board (PCB)

SCIP Guidelines for the Minimum Information Required in a Basic Article

• Primary Identifier
• Article Name
• HS Code
• Safe Use Instruction(s)
• Material Category
• Candidate List Substance
• Concentration range of the substance

SCIP Guidelines for the Minimum Information Required in a Complex Article

• Primary Identifier
• Article Name
• HS Code
• Safe Use Instruction(s)
• Occurrences of SVHC component

Grouping of identical products

• Identical function or purpose
• Similar physical characteristics(shape, surface and design)
• Similar chemical composition

Grouping of semi-identical products

The following criteria must be met for semi-identical  to be considered as the same:

• Identical function or purpose
• Contain the same substance(s) from the candidate list
• The identical material or the potential list substance is included in them by utilizing the same mixture category in a subsequent processing phase.
• Similar safe use instructions

Each set can be submitted in one notification using specific primary article identifier.

Quasi-identical articles

O-rings are composed of identical material with an identical component list, but vary in terms of their width, diameter, or color.

As long as the necessary identification details for each identical article are included in the notification, they can be included together in a single SCIP submission.

Quasi-identical Complex Objects

• The units that form a complex object serve a similar purpose and fall under the same category in terms of their article classification (CN/TARIC code and description).
• The complex object is composed of units that share identical components and subcomponents, serving the same function or purpose as determined by criterion 1. Additionally, both the complex object and its constituent parts contain articles that meet the criteria for quasi-identical items, ensuring that they are considered the same.
• The instructions for safe use of the complex object's units are identical.

It is possible to submit each set as a single notification by utilizing a unique primary identifier for the main article.

Each set can be submitted in one notification using specific primary article identifier

SCIP Identification

It is advised to make a SCIP notification for every group of quasi-identical smartphones such as 100-1, 100-2, and 100-3, instead of submitting a notification for each individual unit.

Image Reference: https://echa.europa.eu/scip

How can they be reported?

• To describe the primary identifier of an article in a SCIP notification, a specific type and value must be used. Other identifiers may be added as secondary identifiers. It's important to note that the primary identifier cannot be modified in the future, as it serves as a critical reference for identifying updates in the system.
• For items that are "fully-identical" or "quasi-identical," a primary article identifier can be established using a representative article identifier. In the case of "quasi-identical complex objects," a representative article identifier for the set of items should be used.
• At minimum, a primary article identifier that can describe the set of quasi-identical complex objects is necessary for complex objects.

Single-Unit Submissions Not Necessary

• Avoid submitting notifications for individual units placed on the market.
• Submitting separate notifications for each unit would be redundant and against the requirements of the WFD (Waste Framework Directive), which calls for one notification per article rather than per unit.
• Instead of submitting separate notifications, companies should provide identifiers or make them available in the supply chain, which would allow users to search the SCIP database for information related to a particular product placed on the market.

Article Identifiers for SCIP Notifications

The system is designed to be adaptable to various article identifier standards. If necessary, additional identifiers can be included in the 'Other Article Identifiers' section. However, it is important to ensure that this section contains all relevant catalogue numbers to enable users to locate the articles in the database.

To ensure accuracy and consistency in identification, it is crucial to use a standard identifier as the primary article identifier:

1. For effective communication,  it is crucial that consumers and waste operators can identify the article in question with clarity.
2. You, as well as other downstream users who may find the information in your SCIP notification useful, can establish a connection to your notification and any reported variations through SSN or referencing.

To take advantage of grouping options, it is crucial to include the correct commercial identification elements (names and alphanumeric identifiers) of each subgroup of fully identical articles that are made available or placed on the market in a SCIP notification. A good practice is to include both standard identifiers and characteristics as other article identifiers to accurately report different variations for quasi-identical articles.

When utilizing 'grouping' options for quasi-identical complex objects, it is crucial to note that article identification will occur at the level of the 'set of units,' rather than individual units.

Assist waste operators and consumers in clearly and definitively identifying the specific article.

• To enable consumers to link the submitted safe use information to articles or complex objects placed on the EU market, adequate commercial identifiers may need to be provided. This is particularly important if these identifiers are available to consumers through product labels, catalogs, or other means.
• It is crucial that waste operators and consumers can definitively identify the specific article being referred to.
• For articles or complex objects placed on the market for consumers, it is necessary to include an identifier that is available to consumers (such as the European Article Number, or EAN) in either the 'Other Identifier' field or the 'Primary Article Identifier' field. This will ensure that consumers can definitively identify the article or complex object for which the submitted information is intended.

There are two methods for simplifying communication of SCIP information within the Supply Chain:

1. Simplified SCIP Notification (SSN)

• The SSN provides a simplified approach to referring to information that has already been submitted to ECHA. This is accomplished by submitting the applicable SCIP number exclusively, thereby eliminating the need to prepare a dossier. The submission can be completed via the ECHA Submission Portal.
• Pre-condition: obtaining the SCIP number for the SCIP notification of the item or composite entity that has already been submitted to ECHA. This information can be acquired, for example, as a component of the data to be supplied by your supplier pursuant to REACH Art. 33(1).
• Primary audience: Distributors operating within a supply chain.

Target audience: Distributors.

Fundamental requirement: The product delivered should be the same as the product received.

It is not mandatory to create your own dossier.

The distributor should refer to the supplier's notification and is not required to submit any updates themselves.

How does the SSN function?

 

2. Referencing

• Referencing can be achieved by utilizing a SCIP number, which can either be supplied by a supplier or one that has been assigned to a previously notified article.
• Only the SCIP number for the referenced article or component needs to be provided.
• Referencing is essentially a connection or link between a SCIP number from a previously submitted notification and a complex object notification that references it.

Target group: Manufacturers and assemblers

Main condition: Modifications to the physical shape or makeup of the reference article are not allowed; The product must become part of a complex object.

While generating a SCIP notification for a composite entity, it is possible to refer to an item that already has a SCIP identification number.

Through referencing, you establish a connection between your notification and the supplier's notification along with their subsequent updates.

Referencing in a SCIP dossier

The ECHA has developed a referencing feature in the SCIP dossier that enables referencing of already-submitted SCIP data. This feature can be used by complex object producers and assemblers to prepare the IUCLID dataset for a SCIP dossier by reporting a SCIP number that refers to previously-submitted information in the database.

For instance, upstream suppliers may provide SCIP numbers as part of the information required under REACH Article 33(1).

Simplifying submission of data

• Third-party entities can submit data on your company's behalf, subject to intra-party agreements, through the "foreign user" concept.
  
• Establishing guidelines for reusing data submitted by a supplier
  

1. 1. Simplified SCIP Notification (SSN): If the article remains unchanged, the duty holder can utilize the SSN by referring to the data submitted by their supplier, instead of creating a dossier. This option is particularly helpful for distributors.
   2. Referencing: If an article, which has already been notified by the supplier, is integrated into a complex object, the duty holder can refer to the submitted data without the need to re-enter it.

Hierarchy and layers

Minimize redundant layers of components and sub-components. A highly intricate hierarchy does not necessarily enhance the identification of articles containing substances on the Candidate List, especially for most common products.

For most products, two to five layers of components may be adequate, while for the most intricate products, the number of layers should be minimized, with no more than seven layers ideally.

ComplyDoc: Offers System to System automatic submission of SCIP information

 

Ahmed Sakr

Product Compliance Consultant 

ComplyMarket UG (haftungsbeschraenkt)