How to save time and money on your SCIP notification
With the notification obligation for articles containing substances of very high concern (SVHC) resulting from the REACH regulation, many companies are faced with a major task. Now it is necessary to enter the products and complex objects containing these chemical substances from the candidate list into the SCIP database. The compilation of the necessary information for the SCIP notifications must be done as efficiently as possible in order not to make the effort too great.
We have compiled ten essential pieces of advice to help you save time and money when preparing the SCIP notification for your SVHC, as well as avoid annoying mistakes.
The following are the most important tips you should bear in mind.
1. Keep the goals of the SCIP database in mind
The SCIP database, a consequence of the REACH Regulation, aims to provide users and processors in waste treatment with relevant information on hazardous chemicals in articles and complex objects throughout their life cycle in a transparent way. The database is administered by the European Chemicals Agency (ECHA). When compiling the data for your dossier, it is helpful to keep this goal in mind at all times. This will give you a clear focus on the really important data.
2. Work with your suppliers and customers
Good cooperation across the entire supply chain ensures simplification. This reduces the effort for compiling SVHC data and avoids unnecessary duplicate entries.
3. Use the method of referencing
When referencing, you can refer to existing data from your suppliers and from your own company. This method particularly facilitates data management and reduces complexity. You only need to submit data for a product once and can refer to existing entries. Updating submitted data also renews the notifications to which it refers.
4. Use the simplified SCIP message (SSN)
The Simplified SCIP Notification (SSN) facilitates the compliance with the SVHC notification obligation of certain companies within the same supply chain. This includes, for example, distributors who are not importers. They do not have to create their own dossier. Suppliers share the SCIP number of their products and distributors should ask their suppliers for this number.
The simplified declaration can also be used by companies of the same group of companies.
5. Note relevant information for SCIP reporting
The most important data for the SCIP notification allow a clear identification of the articles or complex objects. This includes a precise indication of the substances contained, which are on the candidate list, as well as the range of concentration and the location of these substances in the article or complex object. Furthermore, information is necessary for the safe use of the articles, as well as for waste treatment.
Analogous to point 1 of these tips, it is important to always provide sufficient information to be able to realise the goals of the SCIP database.
6. Enable clear identification of the products
Provide a clear and unambiguous identification of the item or product to enable searching by SCIP database users. It must be possible to distinguish it from other items in the database and to assign it unambiguously. To do this, you should specify an exact article category and enter a brand name or the model as a supplement to the name of the product under the heading "Other Names". In addition, you have the option of entering article numbers, e.g. EAN and catalogue number under "Other article identifiers" as a supplement to the primary article description.
Furthermore, it can be helpful to enter further specific characteristics and properties, as well as to add a photo of the product in the SCIP database.
However, it is always important to make sure that the information is entered in the correct field. This way it can always be found easily.
7. Provide sufficient information for safe use
Ensure that you provide sufficient information for safe use throughout the life cycle of the products. Particularly relevant is the information required for safe waste management.
This includes the ability to accurately identify the substances that are on the candidate list, their concentration range and the exact location in the article.
8. Only products and objects must be reported
SCIP declarations are only required for products and objects. Substances and mixtures are not included in the scope. In unclear cases, the assessment must be made according to Chapter 2 and Annexes 3 and 4 of the Guidance on Requirements for Substances in Articles and using examples in the Q&As published on the ECHA website (e.g. Q&A 1292).
Manufacturers, producers, distributors and importers are responsible for deciding whether the product is an article.
Notifications need only be submitted for articles and complex objects containing substances on the candidate list.
9. Use simple and clear hierarchies
In hierarchies it is important not to become too complex. A small number of levels in complex objects, which is necessary for the identification and localisation of articles containing substances from the SVHC candidate list, is sufficient. If too many levels are used, unnecessary information complicates the search for substances from the candidate list.
10. Check the dossiers before transmission
Have your dossiers checked with the "validation assistant" in IUCLID before sending the notification. You can also use the plausibility check in the ECHA portal. ECHA is not authorised to delete incorrect notifications, so it is necessary to check the quality of the data before submitting the notification.
Keep in mind that the publicly available information from the database is potentially viewable by users of the database, such as consumers, waste managers, non-governmental organisations and public authorities. Incomplete information does not help to fulfil the objectives of the SCIP database.
Consistently following these ten tips will not save you the effort of entering the SCIP database, but it will help to make the effort more efficient. In this way, you optimise your time investment and avoid mistakes that require time-consuming reworking.