Scip Legal Requirements

For more information, contact Tetra Tech`s team of experts at scip@tetratech.com. We can help you define the steps you need to take when preparing the SCIP so that you can ensure your continued access to the EU market. The EU WFD and SCIP database complements existing reporting obligations managed under REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals). The same companies are in scope. ECHA has set three objectives for the database: SCIP Working Procedures – we propose to create work instructions to define your internal processes and procedures to ensure that products imported into the EU comply with SCIP reporting requirements. This includes meeting requirements when SVHCs are added to the candidate list (historically every 6 months), as well as meeting SCIP notification requirements at the earliest stages of product development. SCIP reporting requires an EU legal entity and an ECHA IT account. We can help you create an account and designate the CNEC as a “foreign user” so that the CNEC can notify on your behalf. SCIP Notification Data Mapping – We also offer SCIP notification data mapping services. We hold workshops with stakeholders to review mandatory and optional data requirements, and then associate each field with one of the following areas: SCIP requires any company that manufactures a product in the EU and/or imports a product into the EU to report all chemicals of concern in its products to the SCIP database. While the underlying legal requirements for SCIP reporting technically only apply to companies with legal status in the EU, all third-country suppliers who manufacture components for products that are then sold on the EU market will bear a significant share of the overall regulatory and financial burden. The European Union`s SCIP database requirements apply to almost all companies that manufacture or sell products containing SVHCs above the threshold in Europe. The following article providers are required to provide information to ECHA: These system specifications and regulatory approaches define the requirements and inform about the specific actions you need to take.

We can already conclude that the efforts are motivated by two facts: REACH contains a number of different requirements. For example, companies importing more than one tonne of a substance into the EU must register that substance for use. Companies that import less than this quantity are not required to register, but must comply with the authorisation and restriction rules of the REACH Regulation. There are also requests for information only for report articles: Use the following flowchart to quickly determine whether you should send a SCIP database notification. Manufacturers and suppliers who do not place products directly on the EU market are not required to submit them, but should support all actors in their supply chain that need to be declared. The United Kingdom has not implemented the obligation to notify the SCIP database and the WFD is not annexed to the Protocol on Northern Ireland. Therefore, legal entities established in the United Kingdom are not required to contact the SCIP database directly. To further strengthen your SCIP readiness, Tetra Tech can offer expert support. While CISP is a new reporting requirement, Tetra Tech has supported similar product compliance reporting requirements for over 20 years. We have the experience and expertise to help you meet the challenges of compliance reporting.

These general information requirements are divided into specific fields that populate the database. Tetra Tech offers self-paced online CISP training to help you train your staff to meet data entry requirements. Check out our other similar courses for examples of how we are already helping companies meet various compliance reporting obligations. The trigger for reporting an article falling within scope is currently derived from the SVHC candidate list of the Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), but the data requirements for the SCIP database, triggered by the EU Waste Framework Directive (WFD), are very different from those required by the REACH Regulation. On 16 December 2020, ECHA reported that 50 days after the launch of the SCIP database, companies across Europe had submitted just over 2 million notifications. As the database points out, 97% of these reports to the SCIP database used IPC-1752B to collect full material declarations and regulatory declarations of conformity from the company`s supply chains. You can find notifications based on IPC-1752B at the SCIP database of all sectors. The majority of these SCIP notifications, more than 1.4 million notifications (74%), were made by companies supplying mechanical products.

Automotive suppliers used IPC-1752B to prepare and submit over 420,000 SCIP reports (22 per cent), and aerospace suppliers used IPC-1752B to prepare and submit over 82,000 SCIP reports (6 per cent). Any company in any sector can use IPC1752B to exchange information with its supply chains in a format that meets the data requirements of ECHA`s SCIP database. In addition, IPC-1752B-based notifications to the SCIP database were made by companies from all EU Member States in Europe. Companies in each of the 27 EU Member States used IPC-1752B to collect supplier declarations and prepare SCIP notifications. Member States are required to transpose the requirements of the SCIP into their national law, the application of which is the responsibility of those Member States. National transpositions and deadlines for each Member State are available online at EUR-Lex. Implementing measures for the Waste Framework Directive vary considerably from one Member State to another, including fines and custodial sentences. The European Union (EU) Waste Directive 2008/98/EC, commonly known as the Waste Framework Directive (WFD), entered into force in July 2018. The WFD sets requirements for waste management, recycling and recovery of products manufactured, supplied or imported into the European Economic Area.

As part of these requirements, the WFD stipulates that any article containing substances of very high concern (SVHCs) must be notified to the European Chemicals Agency (ECHA) so that this information can be made available to waste operators and consumers. IPC-1754 Materials and Substances Declaration for Aerospace and Defense and Other Industries specifies requirements for the exchange of materials and substance data for products between suppliers and their customers for aerospace and defense and other industries with deep supply chains and complex BOMs. For businesses, the most relevant difference between REACH and the EU WFD is the data requirements for the companies involved, as shown in the graph below: Your team may already have a robust product compliance program, or you may simply be learning about the requirements your organization needs to meet. Regardless, when new compliance regulations are introduced, the requirements can seem overwhelming, especially if you`re dealing with a huge supply chain. You can prepare now by analyzing your supply chain to be ready for the new SCIP requirement when it comes into effect. If your product contains substances of concern, you may be able to avoid duplication of preparation for REACH and SCIP. Working with compliance experts or choosing the right compliance tool can help you meet several regulatory requirements. Below is a list of compliance tool solution providers verified by IPC. Ask your customers what vendor reporting deadlines they have set for SCIP. They should also ask whether they need the bare minimum legally required data, such as the names and identifiers of chemicals and articles of concern, or whether they also request additional information. To ensure compliance with these two requirements, businesses must determine whether they are subject to such obligations.

To this end, companies must determine whether substances of very high concern are present in the products they place on the market. However, they do not always have the information internally or there may be doubts about the reliability of the information available.