• lead, for instance, that is used in copper or aluminum alloys (used in connectors, housing, cables, etc.)
• plasticizers (phthalates), such as DEHP (injection-molded plastic parts, interior and exterior cladding, seals, etc.)
• flame retardants such as DecaBDE (car upholstery, PCBs, insulation, housing for electrical and electronic equipment etc.)
• binders or release agents and stabilizers such as dodecamethylcyclohexasiloxane (plastics, paper, paints, inks, coatings, cleaning, and polishing agents, etc.)

There has been an obligation to report SVHCs to customers since the REACH Regulation came into force in 2007. This obligation is often mixed up with the more recent requirement for SCIP database reporting. However, SCIP involves an additional reporting requirement for a product-related database that is a result of the Waste Framework Directive. If you report substances in the SCIP database, this does not automatically mean you have complied with the REACH reporting requirement.

This more recent requirement for reporting SVHCs in the SCIP database is only related to REACH insofar as consumers’ “right to ask” is enshrined there in Article 33(2). According to this, consumers have a right to obtain information about which SVHCs are contained in a product in a concentration of over 0.1% weight by weight. Manufacturers need to make information available within 45 days or they may have to pay a fine. Previously under the REACH Regulation, consumers could only obtain a list of SVHCs contained in an article which did not contain details of their amounts or the components which contained them. That has changed since the SCIP database was introduced. From now on, consumers can scan a barcode on articles when shopping and immediately obtain information from the SCIP database that tells them where SVHCs are found in a complex product. 

The German Federal Environment Agency has developed the Scan-4Chem app to make information about chemicals of concern accessible to the public. The app accesses data on the European AskREACH database. Companies can also use this to answer consumer requests about end products more conveniently, which enables them to comply with their obligation to provide information. AskREACH is a voluntary service that only contains information about end products with a barcode.

However, the SCIP database is mandatory for all articles that contain SVHCs in a concentration of over 0.1% weight by weight. This requirement not only applies to the end product but to all articles. The primary purpose of the database was ultimately not to help consumers make more informed purchases but to provide information for recycling companies, so they know, for example, whether waste plastics contain flame retardants that are harmful to human health or the environment and that are prohibited under REACH Annex XIV. This type of waste plastic would no longer be recyclable because prohibited SVHCs must not be allowed to re-enter the materials cycle.

A Guide and a Candidate List Package are available from the ECHA to help companies complete reporting requirements for Substances of Very High Concern (SVHCs). This package is compared against the substances on the REACH Candidate List and is updated whenever the Candidate List is changed. This usually happens twice a year. Usually, new substances of concern are added, and the list is constantly growing.

The ECHA has provided a harmonized IUCLID interface for transmitting data to the SCIP database. This software tool is already being used by many companies when they have to create registration dossiers for chemicals in conformity with the REACH Regulation. Further systems are connected via an interface, such as the CDX system. This is a data management solution developed by DXC Technology, which can be very helpful in ensuring you meet SCIP reporting obligations. The system works in tandem with the IMDS and can be used in any sector. It enables manufacturing companies of all kinds to collect, analyze and process all the data they need for materials compliance. Conflict minerals can also be reported, which is not possible in the IMDS.

Since January 2021, many automotive companies have also been required to transmit details of SVHCs they use to the new SCIP database as well. For this reason, IMDS Release 13.0 onwards has included new attribute fields and an interface from the IMDS to the SCIP database. You can enter the SCIP numbers and the SCIP submission numbers for articles and complex objects that were submitted to SCIP differently than via the interface provided in the IMDS. If you use the IMDS for submitting data to the SCIP database, these boxes are populated automatically.

SVHC reporting obligations are particularly challenging for the electrical and electronic sector. For example, according to REACH, conductor plates are defined as “articles” containing several hundred-part categories with a multitude of electronic components. These mostly weigh between two milligrams and five grams each. To make matters more complicated, there are often several suppliers for each part category as a result of multiple sourcing strategies.

Please contact us if you would like more detailed advice or need help implementing any of your compliance projects.