ECHA SCIP

The SCIP database, which stands for “Substances of Concern in articles as such or in complex objects (Products),” was developed by the European Chemicals Agency (ECHA) under the Waste Framework Directive (EU) 2018/851. Since January 5, 2021, companies that place products containing so-called Substances of Very High Concern (SVHCs) on the market must submit relevant information to the ECHA. This reporting obligation applies to products that contain SVHCs in concentrations greater than 0.1% by weight, if the substances are listed on the REACH candidate list.

The main objective of the SCIP database is to assist waste management companies in identifying products that contain SVHCs and enable more efficient recycling. Additionally, the reporting obligation aims to encourage companies to reduce the use of hazardous chemicals and replace them with safer alternatives. The information stored in the SCIP database about products and their ingredients is also accessible to consumers, enabling them to make informed decisions.

Examples of Products and Substances with SVHC Reporting Obligation:

• Lead: Used in copper or aluminum alloys for components, housings, cables, and similar parts.
• Plasticizers (Phthalates): For example, DEHP, which may be present in plastic injection-molded parts, interior and exterior panels, seals, and other products.
• Flame retardants: Such as DecaBDE, found in car seat covers, circuit boards, insulation materials, and casings of electrical and electronic devices.
• Binders, release agents, and stabilizers: For example, dodecamethylcyclohexasiloxane, which may be present in plastics, paper, paints, inks, coatings, and cleaning and polishing agents.

SVHC Reporting Obligation: Difference between REACH Reporting Obligation and SCIP Database The SVHC reporting obligation to customers was introduced in 2007 with the REACH regulation and is often confused with the newer reporting obligation in the SCIP database. However, it is important to understand that the SCIP reporting obligation is a separate requirement arising from the EU Waste Framework Directive. This database not only serves REACH reporting but also provides additional information on the use of Substances of Very High Concern (SVHC) in products.

The connection between the REACH Regulation and the SCIP database is relevant in that the REACH Regulation, in Article 33(2), establishes a consumer right to information. Consumers have the right to receive information about SVHCs in products that are present at concentrations greater than 0.1% by weight. Companies are required to respond to such inquiries within 45 days, or they risk fines. Until now, companies were only required to provide consumers with a list of SVHCs present, without specifying the quantity or the specific component. However, this changes with the introduction of the SCIP database.

The SCIP database is primarily used by recycling companies to determine whether hazardous or environmentally harmful substances, such as flame retardants banned under REACH Annex XIV, are present in waste materials like plastic. These waste materials can no longer be reintroduced into the recycling loop if they contain banned SVHCs. The reporting obligation in the SCIP database applies to all products with SVHCs above the 0.1% threshold and covers not only the final product but also any contained articles. The aim of the database is mainly to support recycling companies and is not primarily focused on helping consumers when purchasing products.

Services for the SCIP Database Do you need assistance with your reporting obligations? We offer comprehensive services and consulting on REACH, SCIP, and chemical management. This includes analyzing your data sheets, gathering information from your suppliers, creating SCIP dossiers, and much more.

Contact us and let us know how we can assist you!