On September 9, 2019, the European Chemicals Agency (ECHA) announced the establishment of a database of Substances of Concern In Articles, as such or in Complex Products (SCIP). The SCIP is a database that will hold information on products that contain substances of very high concern (SVHC). Companies that sell or import products into the EU will be required to submit details for products containing SVHCs to the SCIP database.
EU Regulation
While the database will not be published until 2021, a prototype will be released in early 2020. There is currently a user test group working on the database and multiple stakeholder workshops are running to ensure a smooth implementation.
The EU regulation states that companies supplying products/components to EU sellers or companies importing products into the EU that contain SVHCs above a concentration rate of 0.1% will have to submit information about those substances on the SCIP database.
The SCIP database will serve three purposes contributing to a more circular economy:
- Decrease the generation of waste containing hazardous substances by supporting the substitution of substances of concern in articles placed on the EU market.
- Make information available to further improve waste treatment operations.
- Allow authorities to monitor the use of substances of concern in articles and initiate appropriate actions over the whole lifecycle of articles, including at their waste stage.
SCIP Database Required Information
The SCIP will require companies to provide specific information about the material makeup of their product containing SVHCs. Companies will be required to provide:
- Supplier administrative information connected to each product
- Material or article identification information
- Specific SVHC information
- Chemical name
- Concentration amount
- Location of the chemical within the article.
In addition to the required information, companies are encouraged to disclose additional information about their due diligence process.
Companies In Scope of the SCIP Regulation
The regulation will require companies throughout the supply chain to report information into the SCIP database. Examples of companies include:
- EU producers and assemblers
- EU importers
- EU distributors
ECHA outlined that retailers who are selling articles directly to consumers will not have to submit information on the SCIP database.
Due Diligence Process
While the SVHC list is not yet confirmed, the process flow of product due diligence for SCIP reporting is similar to that of other chemical regulations.
The process starts with supplier scoping. The goal of supplier scoping is to identify the products within a supply chain that are imported or sold in the European Union. Then all suppliers related to those products must be identified.
Once scoping is complete, a detailed assessment is created that includes survey questions and secondary data collection. A supplier who acknowledges they supply a product that includes SVHCs should be prompted to include secondary documentation that includes the SCIP required information. Documents that may contain this information include:
- Full Materials Disclosure (FMD)
- Laboratory Test Report (LTR)
- Safety Data Sheet (SDS)
- Certificates of Compliance (COC)
Once suppliers have completed the assessment, key points of risk should be identified. Incomplete responses, inaccurate product documentation, and inaccurate chemical concentration information are all examples of red flags. Appropriate next steps should be taken to mitigate risk. The steps taken to mitigate risk is a good example of something to include as additional information in due diligence reporting.
Penalties for Non-Compliance
Penalties for non-compliance have not been outlined at this point. It is assumed that non-compliance violations will follow that of other EU chemical regulations like EU REACH and EU RoHS.
Resources
If you are actively running compliance programs for other EU chemical regulations like REACH and RoHS, this is a great opportunity to get started on SCIP compliance. Give yourself ample time for data collection. If you’d like to speak with a chemical regulations specialist, click the button below.
Also, the ECHA has a detailed outline of the regulation timeline and an FAQ section of their website that you can access here.
