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EU Article Suppliers Shall Submit SCIP Notification on the SVHC in Articles from 5 January 2021

From 5 January 2021, if SVHC substances are present in an article placed on the EU market in a concentration above 0.1 % w/w, the supplier of that article needs to submit a SCIP notification to ECHA (European Chemicals Agency) under Article 9(1)(i) of the Waste Framework Directive (WFD, Directive 2008/98/EC).

The information shall be submitted to the SCIP database (“Substances of Concern in Articles, as such or in Complex Objects (Products)”).

The following suppliers of articles need to submit the SCIP notification to ECHA:

  1. EU producers and assemblers;
  2. EU importers;
  3. EU distributors of articles and other actors who place articles on the market.

Those not covered by the obligation to submit the SCIP notification to ECHA are:

  1. Retailers and other supply chain actors supplying articles directly to consumers;
  2. Companies outside of the EU.

Companies outside of the EU are not subject to the SCIP notification obligation and are not allowed to submit SCIP notifications. However, a non-EU supplier of articles should support its EU customers by providing them with the necessary information about the presence of SVHC substances in the supplied articles.

The SCIP notification under the WFD Directive complements the current SVHC communication and SVHC notification under the REACH Regulation. These obligations are different in criteria, actors concerned, information to provide:

Table - Comparison of SCIP Notification, SVHC Communication and SVHC notification

  SCIP Notification SVHC Communication SVHC Notification
Application Date From 5 January 2021 From 1 June 2007 From 1 June 2008
Legal Basis WFD (Directive 2008/98/EC), Article 9(1)(i) REACH (Regulation (EC) No 1907/2006), Article 33(1) and 33(2) REACH (Regulation (EC) No 1907/2006), Article 7(2)
Obligation Article supplier provides information to ECHA Article supplier provides information to recipients and consumers Article producer/importer provides information to ECHA
Criteria (Threshold) SVHC > 0.1% SVHC > 0.1%, and SVHC quantity > 1 tonne/year
Actors Concerned - EU producers and assemblers, - EU importers, - EU distributors of articles and other actors who place articles on the market. - EU/EEA suppliers of articles - EU/EEA producers, - EU/EEA importers.
Minimum Information to Provide (1) Identification of the article; (2) Name, concentration range and location of SVHC substance in the article; (3) Safe use information; (4) Information to ensure proper management of the article once it becomes waste. (1) Name of the substance; (2) Safe use information. (1) Identity and contact details of producer/importer; (2) Registration number if available; (3) Identity of the substance; (4) Classification of the substance; (5) Brief description of the use of the substance; (6) Tonnage range of substance.

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