FLUKE
Kimball Electronics
Tolomatic
Industrial Scientific
AHEAD
roboception
FLUKE
Kimball Electronics
Tolomatic
Industrial Scientific
AHEAD
roboception
By Acquis Compliance | Wed Feb 1 2023 | 2 min read

Table of Contents

Brief Introduction to SCIP submissions

The SCIP database, created under the EU Waste Framework Directive (EU) 2018/851, mandates companies in the EU to report information about articles in their products that contain substances of very high concern (SVHCs). The reporting requirement has been extended to the entire European Economic Area (EEA), which encompasses 27 EU member states and Iceland, Norway, and Liechtenstein of the European Free Trade Association (EFTA). EFTA states could submit notifications to the SCIP database starting November 7, 2022, as the database was updated to accommodate their submissions.

What are the SCIP Reporting Requirements

As of January 5, 2021, the SCIP database became mandatory for companies operating in the European Economic Area (EEA). Submitting to the database is enforced by the European Chemicals Agency (ECHA) and requires companies to create an ECHA SCIP-IT account, provide information on their company, products, articles, and substances, and keep their dossiers updated as new substances are added to the SVHC Candidate List or as company information changes.

For instance, consider a mobile phone with numerous parts/articles. If a PCB manufacturer falls within the scope, they must submit or reference a SCIP dossier for the PCB and its components such as IC slots and screws attaching the IC slots to the PCB. This example only covers the PCB component, the manufacturer may need to file dossiers for each part of the PCB, potentially leading to numerous dossiers for a single product.

SCIP submissions must meet IUCLID formatting standards

  • Offline using Internal IT services.
    • Online using ECHA Cloud services.
  • Through a direct system-to-system transfer.

ECHA recommends collaborating within the supply chain, breaking down complex product hierarchies, and referencing existing dossiers to streamline reporting efforts. Acquis has helped manufacturers submit thousands of dossiers directly to ECHA using its S2S capabilities.

What Companies in EEA Countries Should Know

Since the launch of the SCIP database on January 5, 2021, millions of submissions have been received, but many of them were flawed, putting hundreds of companies at risk of non-compliance with EU Waste Framework Directive requirements. To help companies in Iceland, Norway, and Lichtenstein meet SCIP requirements, ECHA issued a press release a month after launch with recommendations, such as collaborating within the supply chain, simplifying complex product structures, and using "referencing".

The practice of "referencing" involves linking a manufacturer's SCIP Dossier ID to their supplier's SCIP ID to fulfill requirements. ECHA improved the SCIP database to accept submissions from EFTA states in November 2022.

Companies in EEA can benefit from the expertise of Acquis, we have been assisting manufacturers with SCIP submissions. Our expertise can help new in-scope manufacturers to meet ECHA's requirements and streamline data management efforts. Acquis offers a SCIP solution specifically designed for manufacturers with complex products along with automated System to System submission capability, the platform enables companies to manage all aspects of SCIP requirements in one solution, reducing the cost and risk of human error.

For more assistance reach out to us to stay compliant.

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SCIP database submissions extended to the entire EEA including Iceland, Norway, and Liechtenstein

SCIP (Substances of Concern In articles as such or in complex Products) is a public EU database managed by ECHA under the Waste Framework Directive . It collects detailed data on articles containing REACH Candidate List SVHCs ≥ 0.1 % w/w to inform waste operators, consumers, and facilitate product circularity.
Suppliers of articles (manufacturers, importers, assemblers, distributors—with the exception of retailers selling directly to consumers) placed on the EU/EEA market that contain SVHCs above 0.1 % w/w must submit to SCIP. As of January 5, 2021 , this applies across all 27 EU member states plus Iceland, Norway, and Liechtenstein .
While EU companies have been subject since January 5, 2021, the requirement was extended to EFTA states (Iceland, Norway, Liechtenstein) from November 7, 2022 , following their integration into the EEA Agreement.
A SCIP submission must include: Article identifiers (e.g. part numbers, TARIC codes) SVHC name, CAS/EC number, concentration range, and location in the article Safe-use and disposal instructions for waste operators Production origin (EU vs non-EU) Each article or sub‑article needing its own dossier even within complex products.
Companies submit SCIP data using IUCLID-compatible files via: The ECHA SCIP-IT portal (online) Offline IUCLID desktop submissions System-to-system (S2S) API integrations—often offered by compliance platforms.
Enforcement is handled by individual member states. In Germany, failure to submit complete or accurate SCIP data can result in fines up to €1 million or even five years in prison . Similar penalties are possible elsewhere in the EEA for negligent or intentional non‑compliance
While REACH Article 33 requires suppliers to inform downstream users about SVHCs above 0.1 % and provide safe‑use instructions, SCIP requires formal dossier submissions into a public database. Both obligations can apply simultaneously for SVHC‑containing articles.