December 28, 2020
The Substances of Concern In articles as such or complex objects (Products) database, better known as the SCIP database, was created to ensure that information on articles containing substances of very high concern (SVHCs) on the European Chemicals Agency (ECHA)’s Candidate List is available throughout the whole lifecycle of products and materials, including the waste stage.
Following our webinar “Europe: How to face the SCIP database entering into force”, we interviewed UL experts Elisa Gavazza, global technical leader, and Silvia Lai, technical manager of Technical Research and Advisory Services, to delve deeper into this important topic.
Below you will find the complete interview.
Question: When would I need to update a SCIP notification?
Lai: Different reasons may require updating a SCIP notification. For example:
- A substance included in your article is included in the SVCH list after Jan. 5, 2021.
- A component incorporated in a complex object is changed along with its SVHC contents.
- Any previously submitted information is changed or needs corrections.
You may update the already submitted SCIP notification. It is also important to remember that the responsibility for the quality, accuracy, completeness and robustness of the submitted data always remains with each duty holder.
Question: If I submit a SCIP notification, will I need to provide information about the presence of the substance along the supply chain?
Gavazza: Companies are still required to comply with their communication and notification obligations under Articles 33 and 7(2) of the REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) Regulation. The scope of the communication is mainly to allow the safe use of the article by the customer. The SCIP notification has been established under the Waste Framework Directive and is intended to ensure that the information about the presence of SVHCs is available throughout the whole life cycle of products and materials, including the waste stage.
Question: If I am an article supplier not within the EU, should I submit a SCIP notification?
Lai: No, EU importers have the duty to provide information to ECHA. Companies outside of the EU are not subject to this obligation and are not allowed to submit SCIP notifications. If you are a non-EU supplier of the article, you should support the EU importer by providing them the needed information on SVHC in the articles you supply. However, the responsibility of the SCIP notification and its content is still up to EU importers.