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Kicking off on January 5th, 2021, the European Chemical Agency (ECHA) will require companies shipping products into or manufacturing in the EU to address obligations under the Waste Framework Directive more commonly known as “SCIP Reporting”. SCIP – or Substances of Concern in Products reporting will require notification to the agency by importers or manufacturers with a record of articles that contain specified substances above a regulated threshold. These requirements will help to ensure information on the articles containing substances of concern are available to waste operators and consumers throughout the entire lifecycle of the product or material. The task is daunting and affected organizations are scrambling to prepare, but a digital solution can help your organization streamline SCIP reporting measures.

SCIP Reporting – Keys to Success

SCIP Reporting requires a better understanding of what products are being sourced or manufactured. This understanding hinges on effective supply chain due diligence, and engaging upstream suppliers and manufacturers for quality information about component and material composition in a timely manner. In addition to chemical composition, upstream suppliers and manufacturers need to provide information related to the agency’s required submission, including safe use handling instruction, and more.

An important factor in the reporting process is product and supplier scope refinement. The first step in scope refinement is to target the focus to products that are either shipped into or manufactured in the EU. Scope can further be refined to focus on components and materials that are most likely to contain ECHA’s listed substances of concern.

The next key to success is ensuring articles that contain substances above the regulated threshold are ready to submit to the agency. Fortunately, ECHA offers a reporting option where you can group articles for submission, where the core reporting elements and article characteristics are shared.

Once the article notifications (or “dossiers”) are ready for submission to ECHA, organizations have two options available – manual submission through ECHA’s IUCLID online platform or via a system-to-system data transfer which can be enabled by a digital platform.

Establishing a Software Solution to Address SCIP

Organizations in need of a tool for SCIP reporting understand the importance of digitally transforming the way they manage their compliance programs and key business processes to simplify the process. Tools such as Product Steward allow users to centralize and automate upstream supplier and manufacturer engagement and data collection to establish smarter, more environmentally sound product design. With the addition of features to such software, to help meet SCIP reporting needs, users can address everything from product regulatory programs for REACH and RoHS to responsible sourcing, and supply chain compliance issues such as Conflict Minerals and product sustainability initiatives.

Through a digital platform, users would have access to supplier questionnaire templates that address Material Compliance, including an option for collecting SCIP-related information from suppliers.

Information collected from upstream suppliers and manufacturers provide SCIP-related inputs that are then automatically analyzed and flagged for inclusion in dossier preparation.

The critical and final part of SCIP Reporting, the submission of dossiers to ECHA, is streamlined by our digital solution by facilitating dossier creation, and optional automatic submission of the data to ECHA and the IUCLID system to complete the reporting obligation.

SCIP Reporting – Take the Next Step

As with most difficult tasks, getting started is often the most challenging. Getting started with preparations for SCIP Reporting, enabled by a digital solution, begins simply with a list of suppliers and associated components and materials. Armed with that supplier and component/material list, organizations can begin the most challenging aspect, supplier due diligence, a task made easier when leveraging a proven digital solution.