Companies have committed significant resources in obtaining the data required for their SCIP notifications, including mapping their existing product, component and material classifications to the categories that will be used in the ECHA submission portal. With the deadline for notifications fast approaching, it is now time to consider how this data will be prepared for submission.
ECHA has published support materials containing examples for simple products, such as a bicycle, which are helpful for companies whose products have a BOM (bill of materials) with only a few layers. Dossier preparation is also straightforward if a company has limited products with articles containing an SVHC above the 0.1% w/w threshold.
However, when a company has thousands of products, with many BOM layers, and many articles containing SVHCs above the threshold, dossier preparation becomes far more complex. In these situations, ECHA has designed SCIP formats that reduce the administrative burden for business by grouping, and by providing the option for submitting simplified notifications and referencing.
Grouping allows a single notification to be made for articles which share the same TARIC code, material and safe use instructions. It is useful for product families or for articles both incorporated into products or supplied as spare parts. Grouping requires versatility in organising the data, which may be done manually or by using automated algorithms.
When a company submits a SCIP notification, the SCIP number generated as a result may be shared with its downstream suppliers. These downstream suppliers may then submit simplified notifications where the product supplied is the same as the product purchased, or reference components used in their products.
Simplified notifications can be made by uploading a spreadsheet to the ECHA submission portal or, as for referencing and regular notifications, submitted system to system, where notifications are made directly from a company’s SCIP software solution. Companies opting for simplified and referenced submissions do not then need to update their notifications as updates are made by their suppliers.
However, the use of another company’s notifications places a dependency on the supplier to ensure that the information associated with the SCIP number provided is accurate and is kept up-to-date. Simplified notifications and refencing also increase the risk of disclosure of confidential and commercially sensitive information.
With the time period between the launch of the database and deadline for notifications extremely short, most companies have chosen not to rely on their suppliers to provide SCIP numbers and instead will submit data on articles and products directly to ECHA’s submission portal. This business decision also reinforces the need for data management systems that allow for flexibility.
Companies should ensure that their SCIP solution is able to manage complexity by grouping notifications using both SCIP data fields and other product attributes; generate both standard and simplified declarations; collect supplier SCIP data and reference SCIP numbers provided, and enable both manual and system to system notifications.
About the Author
Anne Barr, Regulatory and Development Director, Compliance Map
Anne has over 20 years’ experience in the area of sustainability. Advising on product environmental and social compliance and sustainability. Providing regulatory guidance on chemicals, waste and resources management and supply chain transparency.