In the context of the revised Waste Framework Directive (WFD), the European Chemical Agency (ECHA) was tasked to create a database of substances of concern in articles as such or in complex objects or products (SCIP database). The SCIP database was established to improve transparency on hazardous substances in articles.
To ensure that information is gathered and submitted in a uniform manner, ECHA has developed supported IT tools for preparing and submitting compliance data information to the SCIP database:
- A harmonized IUCLID format for preparing SCIP notifications. You can learn more about IUCLID directly on ECHA's website.
- A portal where SCIP notifications are to be submitted to called the SCIP Database
3 Ways to Submit SCIP Database Notifications
First of all, it's important to note that only submissions that comply with ECHA's prescribed SCIP IUCLID format will be processed. All other formats and submissions will not be accepted. To create SCIP notifications in the accepted format, there are three ways you can choose from:
- Prepare and validate data online via IUCLID 6 cloud and submit data to the database manually
- Prepare and validate data offline via IUCLID 6 desktop software and submit data manually
- Prepare data in a third-party system such as your in-house ERP and submit it via system-to-system integration
Out of the three methods listed above, the first two options are more laborious in terms of the manual effort required. Since ECHA provided these tools, shouldn't you use them?
Well, preparing data manually in IUCLID 6 is one option. It is a viable option for companies that have:
- only a handful of products that require a SCIP notification
- fixed products, i.e., the design or the composition rarely changes
- only have a limited number of suppliers
If your company fulfills all the three points described above, that's great! However, having a small number of products does not imply that the submission process is a straightforward one. You have to bear in mind that, even if your products don't change, the Candidate List of SVHC is updated twice per year. This means you have to evaluate your product portfolio to see if any of your products are affected by the update. Wouldn't it be great if you had a system that does this automatically for you?
In reality, manually preparing SCIP notifications is not a viable option for most companies. Continuous improvements to products through new innovations or adapting products to enter new markets are everyday occurrences in companies. Additionally, there might be supply chain updates such as new suppliers or finding better material parts. Some of these changes might be SCIP-relevant, where you have to update your previously submitted notification.
The Zentralverband Elektrotechnik- und Elektronikindustrie (ZVEI) published an effort estimation required for fulfilling the SCIP database requirement. Their estimation: for a typical article supplier in mechanical engineering with about 2500 products, it would require an additional 23 full-time employees to manually prepare and submit initial SCIP notifications to the ECHA SCIP database. This number does not take into consideration updates!
So far we've described factors you should take into account if you were analyzing whether preparing your SCIP notifications in IUCLID 6 is a viable option. In the next section, we discuss why, even if you only have a handful of products that require SCIP notification, you should consider investing in a third-party solution that integrates with your existing system setup.
Benefits of an integrated solution
The last option, working out of your in-house system, has a clear advantage in terms of efficiency as it significantly reduces manual effort, thus considerably saving you time. Here's why:
- You most likely have all of the data required to prepare a SCIP notification in your ERP system. This means there is no double data maintenance plus you maintain a single source of truth. With an integrated solution, such as opesus EPN, you can configure the appropriate data sources for creating SCIP dossiers. opesus EPN has built-in validation rules to ensure the acceptance of the prepared SCIP notification.
- You can leverage system-to-system communication and submit SCIP notifications directly from your system to the SCIP database. Most SCIP solutions available in the market provide this capability simply because you significantly save time by not having to manually upload notifications to the SCIP database.
- You can let the integrated solution do all of the heavy-lifting for you if they have automation capabilities. Can you imagine a solution smart enough to pick up on product changes and update a previously submitted SCIP notification automatically? opesus EPN does that (and more!) All you have to do is to regularly check your notification monitor* to see the latest status of your product notification.
*This specifically refers to a feature that is available in opesus EPN for SCIP Database format.
Thus, if you are looking for a solution or realizing that there has not been a significant reduction in the effort required to maintain your initial SCIP database notifications, you should consider looking at automation capabilities. With process automation, the possibilities for saving time and effort are significant. Most importantly, you don't have to worry about whether you are no longer compliant with SCIP database because of product changes or entering new markets. Contact us to speak to one of our consultants. They'll show you how you can automate your SCIP notifications.