SCIP notification obligation deadline for EU producers, importers, assemblers and distributors expired on 5 January

As of 5 January, 2021 all European Union producers, assemblers, importers and distributors of articles containing substances of very high concern (SVHCs) on the Candidate List in a concentration above 0.1% weight by weight, are required to submit SCIP notification. More than 5 million notifications were sent to the European Chemical Agency (ECHA). The notification obligation shall be performed in the SCIP (Substances of Concern In articles as such or in complex objects [Products]) database.

Who are covered by the notification obligation?

Suppliers of articles 1 or complex objects (articles joined or assembled), including packaging, which contain substances of very high concern (SVHCs) on the Candidate List in a concentration above 0.1% weight by weight shall perform the SCIP notification.

“Suppliers of articles” as defined by Article 3(33) of the REACH Regulation 2 , are ''any producer or importer of an article, any distributor or other actor in the supply chain who places an article on the market". Therefore, retailers – excluding importing and/or producing retailers – and other actors of the supply chain, who directly supply consumers are not subject to the notification obligation.

Companies outside of the European Union are not covered by the obligation and they are not allowed to submit SCIP notifications. The obligation, as mentioned above, arises at the EU importer.

What to report?

Producers/importers/assemblers/distributors shall report the following information:

  • Identification of the article produced,
  • The name, concentration range and location of the Candidate List Substances in the article,
  • Other information that allows its safe use – notably information related to adequate waste management,
  • Information shall only be provided on those articles, which contain Candidate List substances.

How to report?

Before submitting the notification to the SCIP database, the duty holder must have a valid ECHA account. In case the producer/importer/assembler/distributor does not have an ECHA account yet, they must sign up on the ECHA website.

The submission of information can be prepared in different ways:

  • Online, in IUCLID 3 Cloud;
  • Offline, in IUCLID;
  • Using an IUCLID-compatible dedicated format for SCIP submissions in your company’s own system.

The submission to the SCIP database may be performed:

  • Online at the ECHA Submission portal;
  • Through system-to-system transfer from the company’s own system.

Should you have further questions related to the SCIP notification obligation, Deloitte experts are at your service.

1 Articles are objects which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition.

2 Regulation (EC) No 1907/2006 of the European Parliament and of the Council

3 IUCLID is a free software developed jointly by ECHA and the OECD to record, store, maintain and exchange data on intrinsic and hazard properties of chemical substances. The information submitted to ECHA must be in IUCLID format.

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