From January 1, 2021, the registration of articles in the ECHA database is required. The indicator specifies whether the article is registered in the database.

ECHA Website: https://echa.europa.eu/de/scip

SCIP reporting and SCIP Number

SCIP represents the database of the European Chemicals Agency for Substances of Very High Concern (SVHC).

Substances of Concern In articles as such or in complex objects (Products)

From January 5, 2021, there is an obligation for suppliers of articles containing SVHC > 0.1% (without quantity threshold)

Lieferant von Erzeugnissen bedeutet:

• Producers of articles (including assembly) - Importers of articles

• Dealers of articles (except retailers)

When reporting to the SCIP database, a unique SCIP number is provided.

Difference from REACH

In contrast to the REACH regulation, the obligation applies to all articles without a quantity threshold. The obligation also covers articles containing a quantity below one ton per year.

In Articles 7 and 33 of the REACH regulation

• Articles containing SVHC from the Candidate List in quantities > 0.1% and with a total quantity > 1 ton per year (Art. 7(2-4) and (6))

Legal Background

The "Directive 2008/98/EC on Waste and Repealing Certain Directives," also known as the "Waste Framework Directive," was amended by the "EU Directive 2018/851."

Within Article 9, the establishment of a database by the European Chemicals Agency was included.

Excerpt from the Waste Framework Directive, Article 9:

(1) i) ... ensure that the supplier of an article within the meaning of (REACH) provides the information in accordance with Article 33(1) of the aforementioned regulation from January 5, 2021;

(2) By January 5, 2020, the European Chemicals Agency shall establish a database for the data to be transmitted to it in accordance with paragraph 1 letter i and maintain it. The European Chemicals Agency grants access to this database to waste treatment facilities. It also grants access to consumers upon request.

Regarding information obligations, the directive refers to Article 33(1) of REACH.

REACH Article 33(1):

Obligation to provide information on substances in articles

(1) Every supplier of an article containing a substance meeting the criteria of Article 57 and identified in accordance with Article 59(1) in a concentration above 0.1% by weight provides the purchaser of the article with the information available to him sufficient for the safe use of the article but at least the name of the substance concerned.

Die Umsetzung in nationales Recht erfolgte mit der Anpassung des Chemikaliengesetzes § 16f.

Implementation into national law was carried out through the amendment of the Chemicals Act § 16f.

ChemG § 16f (new) Obligation to Provide Information for Suppliers

(1) Any supplier, as defined in Article 3 Number 33 (...REACH...), placing products (...) on the market is required, starting from January 5, 2021, to provide the information in accordance with Article 33, Paragraph 1 (...REACH...) of the European Chemicals Agency, according to Article 9, Paragraph 2 of the (...Waste Framework Directive...). This provision does not apply to products with a military purpose.

(2) The Federal Government is authorized, by means of a legal ordinance with the approval of the Federal Council, to determine in more detail the manner and conditions under which the obligation under paragraph 1 is to be fulfilled, taking into account the guidelines developed at the Union level for the database.

Obligation for Producers and Importers

Producers and importers must report products for which the obligation to provide information applies to the SCIP database. This also applies to all products in which a corresponding article is installed. For components that are not produced themselves, reference can be made to the notification of the supplying companies.

Obligation for Wholesalers

Wholesalers are also obligated to report traded products to the SCIP database as part of the information obligation. Since they are not producers, they can always refer to the reports of the producers (SCIP number).

Arten der Meldung

In the SCIP database, two types of reporting are distinguished.

SCIP Reporting

For SCIP reporting, complete information about the article, including article number, name, composition, and safety information, must be provided. For articles in which other products are incorporated, reference can be made to those. This reporting is required for all producers.

Simplified SCIP Reporting

Simplified reporting is specifically available for reporting by traders. In this case, reference is made to an existing report submitted by the producer. The identification is done using the SCIP number assigned by the SCIP database during the producer's report. Providing additional information about the product is not required.

SVHC (Substance of Very High Concern) refers to particularly concerning substances. These are chemical substances identified under the REACH Regulation as having especially hazardous properties and impacts on humans or the environment.

Legal Background

REACH Article 33 Paragraph 1:

• Obligation to Provide Information about Substances in Articles

• (1) Every supplier of an article containing a substance meeting the criteria of Article 57 and identified according to Article 59 Paragraph 1 in a concentration exceeding 0.1% by mass, must provide the recipient of the article with the information available to him that is sufficient for the safe use of the article. At a minimum, the name of the relevant substance must be provided.

Obligation for Producers, Importers, and Traders

In accordance with Article 33 of the REACH Regulation, every supplier must provide information that an article meets the criteria of Article 57 and is identified according to Article 59 Paragraph 1. The term "Every supplier" includes producers, importers, and traders.

The following information must be provided at a minimum:

• Whether the article meets the criteria of Article 57 and is identified according to Article 59 Paragraph 1 (REACH identifier)

• Date of the last verification (REACH Date)

• Information about which SVHC (Substance of Very High Concern) is contained in the article

Example

The information is represented in the product attributes within the attribute system "Regulations" (code "Regulations") and the attribute class "ECHA-DB."

Example of ECHA Database in the attributes:

The information "Attribute value 2," "Attribute unit," and "Attribute value description" must not be provided.