The ECHA SCIP database: what suppliers actually have to do

The SCIP database holds information on Substances of Concern In articles, as such or in complex objects (hence the name), and was established under the EU Waste Framework Directive. The idea is straightforward: an SVHC in an article does not stop being present when the article becomes waste, so the people handling that waste, and consumers, should be able to find out what it contains. Suppliers placing qualifying articles on the EU market notify ECHA directly, rather than only answering the question when a customer asks.

The duty falls on suppliers of an article, or a complex object built from articles, containing an SVHC from the Candidate List above 0.1% by weight, and placing it on the EU or EEA market. Producers, assemblers, importers and distributors are all in scope for the articles they place on that market. Retailers selling only to consumers, waste operators, and businesses outside the EU/EEA that are not themselves placing the article on that market, are not directly obliged to notify.

The Waste Framework Directive that creates this duty is an EU directive, and it does not apply in Great Britain. A GB-only business, supplying only the GB market, does not have a SCIP notification duty on that basis, and there is currently no GB equivalent database. That is different from saying the obligation disappears for every UK-based supplier: if you place articles on the EU or EEA market yourself, through direct export, an EU entity, or an EU-based distributor acting on your behalf, that activity can still bring you into scope for the EU market, in the same two-markets pattern covered in our UK REACH vs EU REACH comparison. Confirm your specific position against ECHA's current guidance rather than assume GB status settles the question either way.

A SCIP notification centres on three things:

• Article identification. What the article is, including the identifiers used to find it again, such as a name, category and any production identifiers already in use for the product.
• The SVHC itself. Its identity (name and identifier such as CAS or EC number), the concentration range in which it is present, and where in the article it is located.
• Safe use information. What a downstream user, or eventually a waste operator, needs to know to handle the article safely given the substance it contains.

The detailed data model and format are set out in ECHA's guidance for suppliers of articles, which is the primary source to work from when preparing a submission rather than a general summary.

ECHA has built two mechanisms specifically to stop the same article generating duplicate submissions as it moves down the supply chain. A simplified notification lets a duty-holder reference a notification already submitted upstream for the same article, adding only the fields specific to their own placing on the market, rather than recreating the whole dossier. A separate referencing option lets an assembler point to notifications already made for the individual articles inside a complex object they place on the market, instead of re-notifying each component from scratch. Both reduce the data-entry burden. Neither removes the underlying requirement to have a notification in place for what you place on the market.

• It is per article, not per company. A notification covers a specific article or complex object. A range with many affected products means many notifications, not one blanket filing.
• The Candidate List moves. A substance newly added to the Candidate List can bring articles into scope that were not in scope the last time you checked, in exactly the pattern covered in our SVHC update article.
• Assemblies compound the problem. A complex object built from components sourced from several suppliers inherits a notification obligation for each SVHC-containing component, which is where the referencing mechanisms below earn their keep.
• It sits alongside, not instead of, your other SVHC duties. A SCIP notification does not replace the Article 33 duty to communicate SVHC information to customers on request. They are separate obligations triggered by the same underlying fact.

• ECHA — SCIP database
• ECHA — SCIP: suppliers of articles
• ECHA — Summary of obligations from SVHC inclusion on the Candidate List

This is practical guidance, not legal advice.