The obligation to report products that are put on the EU market and contain SVHCs (Substances of Very High Concern) > 0.1% by weight on article level to ECHA’s SCIP database is more than six months old. Now the dust has settled a bit, let us have a look at how reporting has worked so far.
Based on ECHA’s statement from the end of May, the number of submissions has reached around 12.7 million transmitted by approximately 4,500 companies between October 26, 2020, and May 10, 2021, with a peak in submissions in December 2020 and January 2021. Successfully submitted dossiers amount to around 9 million. The vast majority of these submissions (81%) were done using a system-to-system tool. Taking a deeper dive, we see that only around 60% of the dossiers were in fact “full” dossiers; the rest were submitted using the Simplified SCIP notification, i.e., referring to the full ones.
Still, with industries’ estimations for the numbers of dossiers being in the order of magnitude of around one trillion, it seems there is still a lot more to come. What were the issues that have prevented further dossier submission up to now?
Challenges for Reporting SCIP Dossiers
Some of the challenges for initial reporting of SCIP dossiers have been purely technical, starting with the database itself being unreachable at times. This in turn has caused quite a number of dossier validation failures, as reported by ECHA in their statement on March 25th.
Then there were additional factors throwing a spanner in the works for all companies bringing large and complex products onto the market — a limitation to a maximum of 1,000 components per dossier — fully in effect since April 2021.
These constraints require some ingenuity and hands-on work to fulfil SCIP reporting obligations. Some key steps are:
- Leveraging existing information on product composition and using the option of “jokers” for mandatory field values (such as “no data” for Production in EU statement or the broadest concentration band for the concentration of SVHCs).
- Mapping existing information, e.g., for material categorization to ECHA’s picklist values.
- Compressing BOM structures of large products to a meaningful and manageable layout.
- Leveraging options to simplify reporting like referencing (especially of own sub-parts) and Simplified SCIP notification.
Adding on to that, the dissemination of information is now expected after summer 2021 (for a first impression see here). Thus, it is still hard to predict what the submitted information will look like for a third party.
Key Product Features of the SCIP Database Connector
Hand in hand with our customers, iPoint has been working continuously on providing a SCIP solution to support efficient and effective SCIP reporting despite the given restraints. Key product features include:
- Automated collection of product composition information and SVHC analysis via iPoint Compliance module simplifying the identification of SCIP relevant products.
- Setting of default values for several mandatory SCIP data fields allowing for fast creation of dossiers.
- Automated mapping of VDA classes (if used) to ECHA’s material categories in alignment with automotive industry agreement.
- Various BOM compression settings to report meaningful structures and stay within the limit set by ECHA.
- Further option of referencing own sub-component dossiers to reduce BOM size.
- Easy option for Simplified SCIP reporting to handle reporting obligations of all legal entities in one place.
- Detailed information on submission status to track dossiers and handle database downtimes.
- Easy overview of products and submissions for internal reporting or passing on submission information to customers.
- Bulk submission of dossiers via the system-to-system interface.
Beginning in September 2021, Tetra Tech’s online SCIP training will include a module with more details on using iPoint’s software to integrate your existing solutions, leveraging available data and making it easier for you to bulk transfer data into SCIP. Learn more about the training here.
To learn more about iPoint’s SCIP migration tool, contact iPoint at [email protected].
Dr. Angelika Steinbrecher is a Senior Expert in Compliance, Sustainability & Innovation. She works as a business consultant at iPoint Systems, supporting companies in achieving their compliance and sustainability goals.
This post was first published on the iPoint site as 4 Months of SCIP reporting obligation – what are the experiences so far?