Notification of Substances of Very High Concern (SVHC) in the SCIP database is mandatory since 05.01.2021
The communication of SVHC substances contained in articles has been a much-noticed and much-discussed topic since the introduction of the REACH regulation in 2007. Article 33 of the REACH Regulation stipulates that every supplier of an article must communicate to his commercial customers about SVHCfrom 0,1% (w/w) and provide information on safe use. In addition, every consumer may request information from the distributor of articles about SVHC in products and must receive it within 45 days
SVHC stands for „substances of very high concern“
Since SVHC information has so far only had to be communicated between the distributors and their customers, the amendment of the Waste Framework Directive (2008/98/EC) also took the disposal companies into consideration. In the future, they should have access to the SVHC information on articles and thus be able to make waste treatment more efficient. The implementation in Germany is carried out by § 16f of the Chemical Law.
The information on SVHC in articles is collected by the ECHA in the so-called SCIP database. SCIP stands for „
The SCIP database is intended to help make waste treatment more efficient, reduce the use of SVHCs in articles, help consumers make better purchasing decisions and provide authorities with an overview of the use of SVHC substances on the market.
The communication obligation of SVHC substances in the supply chain and the notification obligation of SVHC substances to ECHA remain unaffected by the SCIP notification.Which products are subject to the notification obligation?
Which products are subject to the notification obligation? The obligation to notify always applies if articles contain a substance of very high concern (SVHC) in a concentration of more than 0.1% mass fraction. In the case of composite products, the notification must always be based on the individual products. A product such as a bicycle consists of hundreds of articles. In the case of complex products, links must therefore be set up to all individual products containing SVHC.
Who has to carry out the notification?
The notification of concerned articles has to be carried out by manufacturers in the EU, importers into the EU and also by EU-based distributors and other actors in the supply chain who place articles on the market. Companies that only supply directly to consumers do not have to notify SCIP. The notification may also be made by third parties, such as asseso AG.
When does a notification have to be made?
Affected products placed on the market in the EU must be notified to the SCIP database from 5 January 2021. The notification must be made on the first placing on the market from the deadline. If substances are newly included in the candidate list, the notification must be made the first time they are placed on the market after inclusion.
What information must be entered?
The data required for the notification exceeds the requirements of Article 33 of the REACH Regulation. Therefore already available information on SVHC communication is often not sufficient.
The information to be provided is:
- Name of the article, article category,
- the name, concentration range and location of the candidate list substances contained therein, and
- other information that will allow its safe use - in particular information ensuring that the product is properly disposed of as waste.
Further information may be added optionally. All entries shall be made in English.
The main difficulty in reporting is the gathering of information. Especially importers often do not have sufficient information on SVHC in their articles and communication with suppliers is often difficult. If it is additionally about complex articles, which themselves consist of several single articles, it often seems impossible to gather the necessary information.
We can help you to detect and report relevant SVHC.