SCIP Regulatory Overview
Under Article 3(3) of REACH, an article is defined as an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition.
As of January 5th, 2021, the EU’s Waste Framework Directive (WFD) article 9(2) mandates that if you manufacture or import articles into the EU, or place those articles onto the EU Market, you must notify those products to ECHA’s Substances of Concern in Products (SCIP) database if the following conditions are met:
- The product contains a substance listed on ECHA’s Substances of Very High Concern List (SVHC)
- The concentration of that substance within an article exceeds 0.1% by weight.
Additionally, there may also be supply chain communication requirements under REACH to notify your downstream users and customers to the presence of identified SVHCS, and provide instructions on safe use.
Compliance Solutions
At H2, we provide a variety of services to help our clients meet their SCIP obligations.
- Carry out a gap assessment and help establish a program for restricted chemistry compliance.
- Engage your suppliers to gather information on SVHCs and other restricted chemistry in the parts used to manufacture your products.
- Compile SVHC data and submit information to the SCIP database on your behalf.
- Consult on changes to the SVHC list and help forecast regulatory risks.
Along with SVHCs and SCIP, there are other EU requirements concerning restricted chemistry in articles, such as the Restriction of Hazardous Substances (RoHS) Directive 2011/863/EU, Persistent Organic Pollutants (POPs) Regulation 2019/1021, as well as specific substance restrictions under REACH.
H2 Compliance offers a full suite of services to help our clients navigate the complex interplay of these regulations. Our experts offer a deep understanding of supply chain data management to address this topic in complex supply chains.