Substances of very high concern are often overlooked once an engineered product has reached the end of its lifespan. ECHA’s Substances of Concern in Products (SCIP) list endeavours to inform disassemblers and waste operators of the chemical hazards present in these products, which may not have been disclosed previously. ECHA’s reporting requirements mean that the database can provide detailed hazard information of product parts, as well as the location of the hazard inside products.
The European Chemicals Agency (ECHA) is the primary agency to oversee all things chemical management in the European Union. They enforce classification and labelling regulation, receive poisons centre notifications, as well as oversee substances of very high concern (SVHCs) within products sold on the EU market. SVHCs are highly regulated due their potential risk to human health or to the environment. Engineered products containing SVHCs must be reported to ECHA to be placed on the Substances of Concern in Products list.
Read on to find out more about the database and your reporting requirements to ECHA.
Under the banner of trade secrecy, manufacturing companies often keep exact chemical compositions of their products confidential, so any disclosure of hazardous substances was previously at the producers’ discretion.
SCIP has been put into place by ECHA to combat this, ensuring that anyone involved in the handling of hazardous or concerning materials is informed about the potential risks. This is especially pertinent for waste operators who are required to handle or disassemble engineered products. They are often uninformed about the existence and the location of hazardous chemicals hidden inside.
For example, cadmium is used as a sacrificial coating on materials to minimise corrosion of the product beneath, and lead is often used in electrical components. Both lead and cadmium have been found to have harmful effects on human health.
The SCIP list serves to aid consumers and waste operators in being aware of concerning materials they might be exposed to. It is also in place as a mechanism to gradually phase out or replace these hazardous materials in products, as well as to help minimise toxic leachate from waste products that end up in landfills.
The SCIP database shares the same infrastructure as the Registered Substances Database and they both report hazardous materials. However, the Registered Substances Database looks solely at individual listed chemicals, while SCIP looks at engineered products and their components, within which hazardous materials can be found.
The SCIP allows users to search for components through a number of ways to maximise effectiveness. You can refine searches by article identifier/reference number, article category, material category, substance(s) of very high concern, concern/reason for inclusion, or simply search by SCIP number. Once you have found your product, you can find the listed components and any SVHCs within.
Producers, assemblers, and distributors of products manufactured inside the EU are required to notify ECHA if their products contain SVHCs. For products manufactured outside of the EU but placed on the EU market, the onus lies with the importer to notify ECHA if there are any hazardous components—on behalf of and with support from non-EU producers.
All products containing >0.1% w/w of an SVHC listed chemical in the smallest component must be reported to ECHA for addition onto the SCIP list. The threshold is often mistaken for >0.1% of the entire product, but this is not accurate. Products with components under the threshold are exempt.
For a more detailed guide on reporting requirements for your company, Yordas Insight provides A Practical Guide to the SCIP Database. This course includes learning resources to help you understand the requirements of SCIP, identify your data gaps, be aware of the data challenges and potential solutions, and identify a data collection strategy.
A stepwise guide on how to upload products onto the SCIP can be found in our webinar on this same topic. In brief, however, you can register products by creating the IUCLID file via ECHA Cloud Services or from your IUCLID desktop or server application, adding the product components and elements of concern. Once the IUCLID file is complete, you can generate a dossier on the ECHA portal and submit your notification. If you need to submit in bulk, ECHA also offers automated system-to-system services.
It is important that notifiers take the time to address all components containing SVHCs, because the effectiveness of the database is reliant on the quality of its data. Problems arise when submissions do not include specific identifiers of articles (including manufacturer details), or do not locate specifically where the hazard (and thus the risk) is in the product. If a product or part is not able to be found, it is often mistaken for being “safe”, which does not reflect reality.
At Chemwatch, we manage our own comprehensive regulatory and chemical database, informed by over 30 years of chemical expertise—and we are well equipped to help you with mandatory reporting. We also have a library of past webinars covering global safety regulations, software training, accredited courses, and labelling requirements. Keep an eye on our Webinar calendar for upcoming Webinars, Mini Briefs and ChemXpress training videos.