Companies are concerned with the new REACH SCIP notification duty in January 2021. Many are unsure of their obligations and what type of data needs to be reported. In this article, we’ll discuss the basic requirements and how your company can upload sample data to get started.
What is SCIP?
SCIP stands for Substances of Concern In (articles or complex objects) Products. This database is the newest requirement added to EU REACH compliance.
There are three reasons the database was created. Firstly, the database was created to better track chemicals entering the European Union. Secondly, its purpose is to drive the use of less toxic alternates and substitutes, and thirdly, protecting workers in recycling and the waste stream is critical.
All three reasons lead to an overarching goal of creating a healthier and safer circular economy. A circular economy in simplistic terms is where safe material inputs become outputs and less waste is produced, continuing the loop until all materials are used completely or to a definitive end. Thus avoiding the waste stream for as long as possible and lessening the burden on raw materials.
If you follow this logic, it is easy to understand how the SCIP database ties together tightly with the latest updates to the Waste Framework Directive.
When is it in Effect?
Producers, importers, assemblers, and distributors placing product on the EU market have a compliance obligation. If the product has an SVHC that exceeds the REACH Candidate list thresholds then a SCIP notification must be submitted. There is a legal obligation to notify the commission. The enforcement of the live SCIP database is January 5, 2021.
Does my Company Need to Submit a Notification?
Your company is only required to enter data into SCIP if your parts or products, articles, and complex articles are above the specified EU REACH thresholds for a particular SVHC. However, if all of your articles are below the threshold, then no reporting is required.
Is There a Practice SCIP Database?
On February 17, 2020 ECHA released the prototype version of the SCIP database. This prototype enables your company to try out the process and submit temporary data for upload. The test data will be cleared during October 2020 and official submittals will begin.
We highly recommend you give the prototype database a try. It would be best to get practice submitting data over the summer before the official database is launched beginning October 2020. Remember the SCIP Notification Duty is Jan 2021!
Moreover, no matter what stage of EU REACH compliance your company is at we can help you build the plan, gather your compliance data, assess your risk, and get the SCIP notifications completed on time.
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