Substances of Concern in Products (SCIP) database reporting began in 2021. However, already in 2023, the reporting process and requirements have seen some changes.
The basic requirements remain the same: If the articles you manufacture or import contain Substances of Very High Concern (SVHC) at greater than 0.1% weight/weight concentration, then you will need to report them to the European Union (EU) using the SCIP database.
However, now that several years of SCIP reporting have been documented and millions of reports have been submitted, the EU has introduced some changes in 2023 to make reporting more thorough.
What is the SCIP Database?
SCIP is the database for information on Substances of Concern in articles as such or in complex objects (Products). It was established under the EU’s Waste Framework Directive (WFD). The SCIP database aims to increase the knowledge of hazardous chemicals in articles and products throughout their whole lifecycle, including the waste stage.
What is the Purpose of SCIP?
With increased knowledge about the hazardous substances in articles sold in the EU, manufacturers and importers can work to create more sustainable products. The SCIP aims to:
- Reduce hazardous substances in waste.
- Encourage industry to substitute safer alternatives.
- Contribute to a more circular EU-wide economy.
The information in the SCIP database will also help waste operators improve waste management practices and will lead to promoting better alternatives both from a waste perspective and from a hazardous substance reduction perspective.
Are There New SCIP Requirements in 2023?
As more companies use SCIP, the database will continue to evolve to include new reporting requirements and new features to help with reporting. Already in 2023, we have seen several changes that may impact your SCIP reporting.
Changes in Who Reports to SCIP
Understanding your SCIP reporting obligations is the first step in successful compliance. You may have obligations if you produce, import, or supply products to the EU. Since 2023, this also applies in the European Economic Area, which includes the EU, Norway, Iceland, and Liechtenstein.
Many companies will also have new contractual obligations to provide relevant product information to their customers even if they themselves do not have SCIP obligations. This reporting can be done with the “foreign user” feature in SCIP. Companies who do not have direct legal obligations in SCIP can enter the SCIP accounts of their EU customers as a “foreign user” and directly enter data into their customers’ accounts, helping them fulfill the reporting requirements in EU markets.
New Candidate List Package
Information on articles and complex objects in your products must disclose where substances of concern are in the products and how they can be handled safely. As of January 2023, there is a new Candidate List Package that can be downloaded and used to enable SCIP reporting.
The new 2023 package contains 479 reference substances and is the basis for reporting on hazardous substances in 2023. It contains the following fields:
- ECHA Substance ID
- Candidate List Status (Direct Entry or Group Member)
- Substance Name
- EC Number
- CAS Number
- Substance CAS Number
Where Can I Find SCIP Reporting Help?
Although SCIP has been in effect for several years now, reporting in the SCIP database is still new for many companies. In addition, the changes SCIP reporting has seen in 2023 may have some companies wondering what their reporting obligations are and how to most effectively meet their requirements.
If you need help with SCIP reporting, here are some of the tasks with which Tetra Tech can help you:
- Determining the optimal set-up of user roles and responsibilities for your organization.
- Serving as your representative in the EU if you are a US-based company and have customers asking you for SCIP reporting.
- Manually submitting data and reports to SCIP using your own accounts.
- Automating reporting to and from the SCIP database.
- Serving as the role of “foreign user” within your SCIP account structure or in your EU customers’ accounts.
- Monitoring the future of hazardous substance reporting requirements.
If you need help with any of these tasks, contact Tetra Tech’s product compliance experts today at [email protected]. We can help you understand the SCIP changes that will affect you, helping you remain compliant at a minimum effort.