SCIP is the European database for information on articles containing Substances of Very High Concern (SVHCs) on the REACH Candidate List above 0.1% by weight when those articles are placed on the EU market.

For electronics manufacturers, SCIP is not simply a submission task. The difficult part is building reliable information about the articles, components, materials and substances inside a product and connecting that information to the correct product structure.

ECHA requires information that identifies the article, the Candidate List substance, its concentration range and location, together with information needed for safe use, including information relevant to the waste stage.

This guide explains what electronics manufacturers need to know about SCIP database submissions and how to build the underlying data workflow.

What Is the SCIP Database?

SCIP stands for Substances of Concern In Products.

The SCIP database was established under the EU Waste Framework Directive to collect information about articles containing Candidate List substances of very high concern.

The database is intended to make information about substances of concern available throughout the product lifecycle, including the waste stage, and to support waste operators, consumers and the transition toward safer and more circular products.

SCIP therefore goes beyond maintaining a simple list of restricted substances.

The notification needs to preserve information about the relationship between an article, the substance of concern and, where relevant, the complex object in which the article is incorporated.

Who Needs to Submit a SCIP Notification?

The SCIP obligation applies to suppliers placing relevant articles on the EU market.

ECHA identifies relevant supplier groups including:

• EU producers and assemblers
• EU importers
• EU distributors
• Other supply-chain actors placing relevant articles on the EU market

The obligation applies where an article contains a Candidate List substance above 0.1% weight by weight.

Retailers and other actors supplying articles directly and exclusively to consumers are treated differently under the ECHA guidance.

For electronics manufacturers, the first step is therefore to determine whether the company and the relevant articles fall within the SCIP obligation.

When Does SCIP Apply?

The SCIP notification obligation is triggered when an article placed on the EU market contains a Candidate List SVHC above 0.1% w/w.

The threshold applies to the concentration of the Candidate List substance in the article. ECHA's SCIP database describes notified articles as containing one or more Candidate List substances above 0.1% w/w.

This makes article-level data important.

A finished electronic product can contain many individual articles and components. A manufacturer therefore needs to understand where the relevant substance occurs and which article contains it.

A useful way to think about the data relationship is:

Supplier → Component → Article → Material → Substance → Product

The exact data structure depends on the product and the SCIP notification, but the underlying relationships need to be understood.

What Is an Article Under SCIP?

SCIP uses the concept of an article from REACH.

An article is an object that, during production, is given a special shape, surface or design that determines its function to a greater degree than its chemical composition.

This distinction matters for electronics manufacturers because a finished product can contain multiple articles.

A product may include components, housings, connectors, cables, fasteners, assemblies and other articles. SCIP information needs to reflect the relevant articles and their relationships.

What Is a Complex Object?

A complex object is an object made up of more than one article.

ECHA's SCIP database can represent complex objects using hierarchical relationships between the top-level product and its components and subcomponents.

For example:

Finished product

→ Assembly

→ Component

→ Article

→ Material containing Candidate List substance

This hierarchy is particularly relevant to electronics manufacturers because product BOMs can contain many levels of assemblies and components.

The compliance team therefore needs more than a substance list. It needs to understand where the relevant article sits within the product structure.

What Information Is Required for a SCIP Notification?

ECHA identifies several important information categories for SCIP notifications.

Article identification

The notification needs information that allows the article or complex object to be identified.

This can include names and identifiers such as part numbers or other identifiers used by the supplier.

Candidate List substance

The relevant Candidate List substance needs to be identified.

ECHA's SCIP information includes the substance name and, when available, EC and CAS numbers.

Concentration range

The notification includes the concentration range of the Candidate List substance in the article.

ECHA's SCIP database uses predefined concentration ranges, including the range above 0.1% w/w that triggers the SCIP notification obligation.

Substance location

The notification needs information about where the substance is present in the article, where applicable.

This is important for products where the same substance can occur in different materials or locations.

Material category

The notification identifies the material in which the Candidate List substance is present.

ECHA maintains the relevant material categories for SCIP notifications.

Safe-use information

The notification may also need information necessary to ensure safe use of the article, including information relevant to handling the article when it becomes waste.

Why Is Supplier Data Important for SCIP?

For many electronics manufacturers, the information needed for SCIP does not originate with the final product manufacturer.

A purchased component may contain an article and material information that the manufacturer cannot determine from the BOM alone.

The workflow therefore often begins with supplier information.

For example:

Supplier information

↓

Component

↓

Article

↓

Material

↓

Candidate List substance

↓

Product

If the supplier provides only a generic statement such as "REACH compliant", that may not provide the article-level information needed for the SCIP assessment.

The manufacturer needs to determine what information is available, what is missing and how the supplier data connects to the product structure.

How Does FMD Support SCIP Data Collection?

Full Material Disclosure can provide a useful data foundation for SCIP because it can provide deeper information about materials and substances than a simple compliance declaration.

For manufacturers already managing FMD, the existing product, component, material and substance relationships may be reusable when assessing SCIP requirements.

See the Full Material Disclosure guide for the broader material-data workflow.

FMD does not automatically make a product SCIP compliant. The manufacturer still needs to determine whether the relevant SCIP obligation applies and whether the available information satisfies the applicable SCIP information requirements.

How Should SCIP Data Connect to the BOM?

The BOM provides the product structure, but a BOM by itself does not provide all the information required for SCIP.

A practical compliance data model needs to connect the product structure with the relevant material and substance information.

For example:

Product

↓

Assembly

↓

Component / Article

↓

Material

↓

Candidate List substance

↓

Concentration and location

This structure helps the compliance team determine which articles require attention and where the relevant substance information belongs.

It also makes future reviews easier when a component, supplier or material changes.

How Should Manufacturers Collect SCIP Information From Suppliers?

Supplier requests should be based on the information needed for the actual SCIP assessment.

A practical workflow can include:

☐ Identify suppliers and components requiring information

☐ Identify the appropriate supplier contact

☐ Request relevant article and substance information

☐ Capture supporting documentation where available

☐ Validate the supplier response

☐ Connect the response to the correct component and product

☐ Identify missing or inconsistent information

☐ Maintain the information for future assessments

The goal is to collect structured information that can be connected to the product rather than treating every supplier declaration as an isolated document.

How Should SCIP Data Be Validated?

Validation should happen before submission.

Manufacturers should check whether:

☐ The article is correctly identified

☐ The Candidate List substance is correctly identified

☐ The concentration range is available

☐ The substance location is identified where required

☐ The material information is available

☐ The article and complex-object relationships are correct

☐ Required safe-use information is available

☐ Supplier information is connected to the correct article or component

☐ The information is based on the appropriate Candidate List reference data

ECHA's validation rules distinguish between business-rule failures that can cause a submission to fail and quality-rule warnings that identify potential shortcomings or inconsistencies.

That distinction is important. A warning and a failed submission are not necessarily the same thing.

How Are SCIP Notifications Prepared?

ECHA has established a harmonised IUCLID format for SCIP notifications.

The ECHA SCIP format page currently provides the SCIP data model, dossier preparation guidance, validation rules and developer information for the IUCLID format. Its published format history currently lists SCIP format version 6.0, May 2025.

Manufacturers should therefore use the current ECHA requirements and tools rather than relying on an older internal template.

ECHA also provides tools and guidance for preparing and submitting SCIP notifications.

Can Previously Submitted SCIP Data Be Reused?

Yes.

ECHA provides mechanisms for reducing duplicate work when relevant SCIP information has already been submitted.

The Simplified SCIP Notification (SSN) allows a supplier to refer to information already successfully submitted to the SCIP database without preparing and submitting a new IUCLID dossier in the same way.

ECHA also supports referencing previously submitted SCIP data within notification dossiers, including references to articles incorporated into complex objects.

This can be particularly important for manufacturers managing complex products with many components.

What Happens When SCIP Data Is Incomplete?

Incomplete data should be treated as a data-quality problem before it becomes a submission problem.

Potential gaps include:

• Missing supplier information
• Unclear article identity
• Missing substance identification
• Missing concentration information
• Missing substance location
• Incorrect material information
• Incorrect article relationships
• Outdated supplier data
• Product structure changes that are not reflected in compliance records

The appropriate response is to identify the missing information and determine how it affects the relevant article and notification.

How Should Manufacturers Manage SCIP Changes?

SCIP information should not be treated as permanently static.

Changes to products, components, suppliers, materials or substance information can affect the underlying data used for SCIP.

A connected compliance workflow can help identify when an existing assessment needs to be reviewed.

For example:

Engineering change

→ affected component identified

→ supplier/material information reviewed

→ Candidate List assessment performed

→ SCIP impact determined

→ notification updated where required

This is why SCIP management should be connected to product and compliance data rather than maintained as a separate spreadsheet.

How Can Manufacturers Reduce Duplicate SCIP Work?

ECHA's referencing mechanisms are one part of reducing duplicate work.

Manufacturers can also improve efficiency by maintaining reusable product and material information.

A stronger process connects:

Supplier data

→ Material data

→ Article data

→ BOM

→ SCIP assessment

→ Notification

This creates a reusable compliance data foundation instead of rebuilding the same information every time a new request or regulatory change occurs.

What Is the Difference Between SCIP and REACH?

SCIP and REACH are related, but they are not the same obligation.

REACH Article 33 concerns communication of information about Candidate List substances in articles to recipients in the supply chain. ECHA states that suppliers of articles containing a Candidate List substance above 0.1% w/w must provide sufficient information for safe use.

SCIP is a separate database notification obligation established under the Waste Framework Directive.

The two workflows can use overlapping underlying substance and article information, but the compliance outputs are different.

For a detailed comparison, see SCIP vs REACH: Key Compliance Differences and Reporting Duties.

What Should Electronics Manufacturers Check Before a SCIP Submission?

Use this as a practical review:

☐ Confirm whether the relevant article falls within the SCIP obligation

☐ Check the Candidate List status of the relevant substance

☐ Confirm the substance concentration is above 0.1% w/w where applicable

☐ Identify the relevant article

☐ Identify the Candidate List substance

☐ Confirm concentration range and location

☐ Confirm the relevant material information

☐ Review article and complex-object relationships

☐ Check safe-use information

☐ Validate supplier information

☐ Check the current ECHA SCIP requirements and format

☐ Check whether existing SCIP information can be referenced

☐ Validate the notification before submission

How Can Regilient Support SCIP Data Management?

SCIP becomes difficult to manage when supplier information, BOMs, material data, substance information and compliance records are maintained separately.

Regilient's environmental compliance platform includes SCIP support and supplier data management capabilities. Its current environmental compliance offering specifically lists SCIP (WFD) with automated SCIP database notification.

Regilient also describes support for supplier data collection, validation and compliance tracking, including SCIP database submissions.

For manufacturers managing multiple material compliance requirements, the broader environmental compliance software workflow provides the wider context.

Building a Reliable SCIP Data Workflow

SCIP submission is the final step in a much larger product-data process.

For electronics manufacturers, the stronger approach is to connect supplier information with the product structure and maintain the relationships between articles, materials and substances.

The workflow becomes:

Identify → Collect → Connect → Validate → Submit → Maintain

That makes SCIP part of the broader product compliance process rather than another isolated reporting exercise.