Suppliers of articles
Suppliers of articles
Companies supplying articles containing Candidate List substances and placing them to the EU market have an obligation to submit information on these articles to ECHA.
Am I affected?
The obligation to submit a SCIP notification covers all articles placed on the EU market containing a substance of very high concern on the Candidate List in a concentration above 0.1 % w/w.
The following suppliers of articles need to provide information to ECHA:
- EU producers and assemblers,
- EU importers,
- EU distributors of articles and other actors in the supply chain placing articles on the market.
Retailers and other supply chain actors supplying articles directly and exclusively to consumers are not covered by the obligation to provide information to the SCIP database.
From which date should information be communicated to ECHA?
As from 5 January 2021, information on articles containing SVHCs (on the Candidate List) in a concentration above 0.1 % w/w placed on the EU market needs to be notified to ECHA.
What information needs to be communicated to ECHA?
Suppliers of articles need to submit the following information to ECHA:
- information that allows the identification of the article
- the name, concentration range and location of the Candidate List substance(s) present in that article
- other information to allow the safe use of the article, notably information to ensure proper management of the article once it becomes waste.
A detailed list of all information requirements is given in the "Detailed Information Requirements" document.
Which data submitted to the SCIP database will be published by ECHA?
The information submitted to the SCIP database will be publicly available and therefore readily available to waste operators to bridge the current gap in the information flow.
ECHA will publish the information, as received, on its website. The quality of the data remains the responsibility of each duty holder. At the same time, ECHA will ensure the protection of confidential business information where justified. For example, the data that allows to establish links between actors in the same supply chain will not be made publicly available.
Know your portfolio of articles
Once you have identified an obligation and you are familiar with the standard information requirements, it is time to look at your portfolio of articles as such or in complex objects (products).
Identify which articles as such or in complex objects contain substances of very high concern on the Candidate List in a concentration above 0.1 % w/w.
Depending on your role in the supply chain, you always need to consider the inputs (articles as such or complex objects received as a recipient) and outputs (articles as such or complex objects placed on the market as a supplier) of your process.
How REACH defines an article
- According to REACH Article 3(3), an article is an object which during production is given a special shape, surface or design which determines its function to a greater degree than its chemical composition.
- A “complex object” is an object made up of more than one article.
- Articles that are assembled or joined together in complex objects remain articles, as long as they keep a special shape, surface or design, or as long as they do not become waste.
- Establish how the article or complex object (product) will be identified in the notification:
- Article name, other names (E.g. Brand; Model; Type)
- Primary Article Identifier, other Article Identifiers (E.g. European Article Number (EAN); Global Trade Item Number (GTIN); Universal Product Code (GPC); Catalogue number; ECHA Article ID; part number.)
- Article category: Identification of the article or complex object from a harmonised list based on function/use (the integrated Tariff of the European Union – TARIC - list, based on the Combined Nomenclature (CN) of Annex I to Council Regulation (EEC) No 2658/87).
- Is the article produced or assembled in the EU?
- Characteristics: Collect the article or complex object’s characteristic(s) that may help to distinguish the reported article or complex object from similar articles or complex objects. E.g. Height; Length; Width; Diameter; Density; Weight; Volume; Colour.
- Define the safe use instructions required for the articles as such and in complex objects. Disassembling instructions may also be included.
- Complex object components: A notification of a complex object will include the information of the components containing SVHCs (on the Candidate List) in a concentration above 0.1 % w/w and the specification of number of occurrences of the linked article in the complex object.
- Collect the information of the Candidate List substance(s) in the article:
identification of the Candidate List substance;
concentration range of the Candidate List substance in the article; and
identification of the material category of the article or the mixture category where the Candidate List substance is present. The Candidate List substance is either present on the material the article is made of or in a mixture incorporated in the article under a further processing activity (e.g. coating).
- Review the detailed list of all information requirements and the SCIP IUCLID format to find the correct path to adapt your data.
- To simplify your duty, you can group quasi-identical articles and complex objects to a certain level into one SCIP notification. For detailed information about these ‘grouping’ criteria, review the information requirements document and the “Key tips for successful SCIP notification” at the SCIP support page.
ECHA has established a harmonised IUCLID format for submitting the required information to the SCIP database.
Please see additional information under our Tools to prepare and submit notifications webpage and our manual “How to prepare and submit a SCIP notification”, available at the SCIP support page.
ECHA has created solutions to refer to data that has previously been submitted to the SCIP database. These approaches facilitate the submission of SCIP notifications and help to prevent redundant data being submitted for the same article. Solutions:
- The simplified SCIP notification (SSN) allows you to refer to information already successfully submitted to the SCIP database, without having to prepare and submit a new IUCLID dossier.
- The use of ‘referencing’ in a SCIP notification dossier. For instance, assemblers refer to notifications already made for the articles that they incorporate into complex objects they place on the EU market.
Please see additional information on the document “Tools to refer to SCIP data already submitted to ECHA”, available at the SCIP support page.
Please see additional information under our Tools to prepare and submit notifications webpage.