Long anticipated, the obligation to provide information on the substances of the REACh Candidate List in the SCIP database at ECHA (European Chemicals Agency) has, in most Member States, come into force today.
This means that producers, importers, downstream users or distributors placing articles on the market which contain SVHCs (“Substances of Very High Concern”) in a concentration of more than 0.1% by mass, must report product and material information via the new database to ECHA as of today. Since the required information must be collected and submitted not only on level of the actual product (e.g. bicycle or computer) but also down to the individual components (so-called “articles as such”), particular importance is attached to data procurement and preparation.
Depending on product portfolio and supply chain complexity, large volumes of data may need to be sourced, evaluated and prepared for submission. Although a “system-to-system” interface can help with the actual data reporting to the SCIP database, practice shows that this actually only brings greater efficiency where complete and conclusive data is available. In our experience, however, it is precisely such procurement and validation of the required data which pose the greatest challenge of the new SCIP obligation. Major difficulties are caused, for example, by the distinction between “Complex Objects” and “Articles as such” (i.e. which levels are to be included in a dossier), the question “Are relevant SVHCs contained in a “Complex Object” or an “Article as such”?” and the assignment of identifiers.
Are you currently trying to manage the SCIP submissions for your company and have questions or need support? Feel free to contact us.