SCIP Database Submissions: A Practical Walkthrough
If your article contains an SVHC above 0.1%, ECHA wants a dossier — not a paragraph. Here's what actually goes into one.
SCIP — the SVHC in Products database, run by ECHA — trips up more teams on process than on principle. The principle is simple: if an article placed on the EU market contains a Candidate List substance above 0.1% weight by weight, someone in the supply chain has to notify ECHA. The process is where things go sideways.
What a dossier actually needs
A SCIP notification isn't a form email. It requires, per article (or complex object):
- Identification of the article — name, category, production/import details
- The specific SVHC present, by its exact substance identity (CAS/EC number where available)
- Concentration range of the substance in the article
- Safe use instructions for downstream users and, ultimately, waste operators
- Whether the article is itself incorporated into another, more complex product further down the chain
That last point matters more than it looks. If your component is built into a larger assembly by your customer, the notification obligation may sit with them, not you — but only if they have accurate data to notify with. Passing incomplete or vague substance information downstream just moves the compliance gap, not the obligation.
Where submissions actually fail
- Substance identity gets vague. "Contains phthalates" isn't notifiable data. ECHA's system expects specific CAS numbers.
- The complex-object question gets skipped. Teams often don't map which of their own components already carry a notification versus which need a fresh one at the next assembly level.
- Updates lag reality. A SCIP dossier tied to a superseded material composition is arguably worse than no dossier — it documents the wrong thing with apparent authority.
Making SCIP a byproduct, not a project
Once material-level SVHC screening is already part of your supplier data process — which it needs to be for REACH anyway — a SCIP notification is mostly a formatting exercise: take data you already hold and route it into ECHA's submission structure. Companies that treat SCIP as its own standalone compliance program tend to duplicate work they were already doing for REACH communication obligations. Companies that treat it as one output of a single substance database don't.