By Harshavardhan SPublished: 2 min read

Table of Contents

If your product contains a Substance of Very High Concern (SVHC) above 0.1% w/w and you're placing it on the EU market, you almost certainly owe ECHA a SCIP submission. This has been a legal requirement since 5 January 2021, and it sits alongside, not instead of, your REACH Article 33 disclosure duty.

Here's the part that's changed recently and matters more than any procedural detail: on 10 December 2025, the European Commission formally proposed repealing SCIP outright, as part of its Environmental Omnibus package. The proposal isn't adopted yet. Your obligations are unchanged today. But if you're planning compliance infrastructure with a multi-year horizon, this is now a live variable you need to account for, not a footnote.

What the SCIP Database Is For

SCIP (Substances of Concern In articles, as such or in complex objects, i.e. Products) was established under Article 9(1)(i) of the EU Waste Framework Directive (2008/98/EC) and is managed by ECHA. It's been operational since 5 January 2021, and exists to:

  • Reduce hazardous waste by encouraging substitution of SVHCs with safer alternatives before products reach end of life
  • Improve transparency for the waste operators, recyclers, and consumers who handle these products once they're discarded
  • Support lifecycle monitoring of SVHC-containing articles, from manufacture through to disposal or recycling

The scale of the database is genuinely large: by 30 April 2026, ECHA had received more than 18 million SCIP notifications from roughly 6,000 companies across the EU. The most commonly notified product categories include machinery and parts, measuring instruments, electrical and electronic equipment, and furniture.

It's worth being precise about what SCIP is not: it's a notification and transparency mechanism for waste treatment, not a market-access gate the way a REACH restriction or authorisation would be. But non-compliance is still a legal breach with real enforcement teeth, covered below.

The Repeal Proposal: What's Actually Changing (and When)

On 10 December 2025, the Commission published its Environmental Omnibus package, six legislative proposals aimed at simplifying EU environmental law. One of them, COM(2025) 986 final, proposes amending the Waste Framework Directive to repeal the SCIP notification obligation entirely.

The Commission's stated reasoning is blunt: it concluded that SCIP has delivered limited practical value relative to its administrative cost. Its own review found that public use of the database is low, the data is too complex for most consumers or recyclers to act on meaningfully, and it duplicates information already available through other channels such as labelling. The Commission expects the Digital Product Passport (DPP) to eventually provide a more effective mechanism for the same underlying goal, communicating substance information through a product's lifecycle. Repealing SCIP is projected to save businesses roughly €225 million annually.

What this means in practice, right now:

  • Nothing has changed yet. The proposal has not been adopted. SCIP notification remains a live legal obligation under the current Waste Framework Directive, and Article 33 REACH disclosure is entirely unaffected regardless of what happens to SCIP.
  • There's no confirmed timeline for adoption. Omnibus proposals like this move through Parliament and Council review, and past environmental omnibus items have taken well over a year to finalise, if they pass in their proposed form at all.
  • Existing SCIP data doesn't disappear even if the repeal passes. The Waste Framework Directive continues to provide the legal backbone for substance information and circular economy requirements; DPP is positioned as the successor mechanism, not an immediate replacement with a hard cutover date.

The practical takeaway: don't stop submitting, and don't build new SCIP infrastructure as though it's permanent, either. If you're deciding how much to invest in dedicated SCIP tooling versus a more flexible substance-data layer that can also feed a future DPP requirement, that decision should explicitly account for this proposal.

What You Actually Have to Report

A SCIP dossier needs to identify the article precisely enough that a waste operator downstream can act on it. Required data includes:

  • Article identification: a unique identifier (part number, EAN, or similar), plus a category code (CN or TARIC) describing what the article is
  • Production origin: whether the article or complex object was produced or assembled inside the EU or not
  • SVHC details: the substance name, CAS and EC number, concentration range, and where in the article the substance is located
  • Safe use and disposal instructions: enough information for the substance to be handled safely at the waste stage

Each SVHC-containing component within a complex article generally needs its own entry. For a single-material article this is straightforward. For a multi-tier assembly, say, an electronic component with a flame retardant in one part and a phthalate-containing cable elsewhere, dossier structure has to reflect that hierarchy accurately, which is where most of the real preparation effort goes.

Creating SCIP Dossiers in IUCLID Format

Submissions go through the IUCLID (International Uniform Chemical Information Database) format, ECHA's standard for chemical data. In practice:

  1. Data compilation: gather accurate, current SVHC data across the article, including complex objects with multiple SVHC-containing components
  2. Dossier preparation: structure the data in IUCLID, organised hierarchically so a multi-component article's substance data maps correctly to each part. ECHA also provides a "Candidate List Package" and a trial service to help test submissions before going live.
  3. Submission: file through ECHA's SCIP-IT portal for manual upload, or via system-to-system (S2S) integration for higher volumes

You'll need a valid ECHA account and, in most cases, the "IUCLID Full Access" role to prepare SCIP notifications. Each successful submission generates a unique SCIP number, which distributors further down the chain can reuse rather than re-submitting the same underlying data from scratch.

A current operational note: ECHA has reported ongoing technical delays in the SCIP dissemination process since the start of 2026. Successfully submitted notifications don't require any further action from the submitter, but published data may lag behind what's actually been filed. Worth knowing if you're checking whether a supplier's submission is publicly visible yet.

Who Needs to Submit

Since 5 January 2021, any company that manufactures, imports, assembles, or distributes articles containing SVHCs above the 0.1% w/w threshold and places them on the EU/EEA market is in scope:

  • Manufacturers and importers carry primary responsibility, regardless of whether the company itself is based inside or outside the EU
  • Distributors supplying into the EU market need to ensure submissions have been made for the products they handle, though they can often reuse an upstream supplier's SCIP number rather than duplicating the dossier
  • Retailers selling only to consumers are generally excluded from the obligation
  • Non-EU companies not placing products on the market directly aren't required to submit, but may do so voluntarily to support EU-based partners in meeting their own obligations. A significant share of the 18 million-plus notifications on file were filed by EU importers acting on data prepared by non-EU suppliers.

Penalties and Enforcement Vary by Member State

SCIP enforcement isn't harmonised at EU level; each Member State sets its own penalty regime under national implementation of the Waste Framework Directive. This varies meaningfully. Germany, for example, permits fines of up to €1 million alongside potential imprisonment of up to five years for serious breaches. Other Member States apply lighter administrative penalties. If you're operating across multiple EU markets, the practical risk profile of a missed submission isn't uniform, and it's worth knowing which jurisdictions carry the sharpest teeth for your specific product categories.

Sector Patterns Worth Knowing

SCIP obligations touch different industries in recognisably different ways:

  • Electronics: flame retardants, lead, and plasticisers in components and cable assemblies are the most frequent triggers
  • Automotive: elastomers, coatings, and cable assemblies carry recurring SVHC exposure
  • Furniture and home goods: formaldehyde, phthalates, and adhesives are common flags
  • Textiles and apparel: azo dyes, hexavalent chromium, and PFAS show up regularly
  • Toys: phthalates, cadmium, and lead remain persistent categories of concern

If your product spans multiple materials or subcomponents sourced from different tiers, treat SCIP exposure as the default assumption rather than something to rule out.

Where This Overlaps With REACH

SCIP and REACH Article 33 disclosure are two separate obligations triggered by the same underlying fact: an SVHC above 0.1% w/w in your article. Fulfilling one doesn't discharge the other. Most compliance teams run both from the same underlying material data rather than maintaining separate processes. Our breakdown of SCIP versus REACH reporting duties covers the distinction in more detail, and our Waste Framework Directive overview goes deeper on the legal basis for SCIP itself.

Where Manual SCIP Processes Break Down

A single SCIP dossier isn't hard. The difficulty shows up at scale:

  • Multi-component articles need per-component entries, and tracking which components have been covered gets error-prone in a spreadsheet
  • BOM changes mean a dossier that was accurate six months ago may not reflect the current product
  • Candidate List updates (twice yearly) can pull previously unaffected articles into scope, with no natural trigger in a manual process to catch that
  • Cross-border supplier chains mean SCIP numbers need to be tracked and reused correctly rather than regenerated, or you end up with duplicate, inconsistent dossiers for the same underlying article

Regilient's platform keeps SCIP dossier data tied directly to your BOM and current Candidate List status, so a component change or a list update surfaces the articles that need a fresh look, and reused SCIP numbers propagate correctly to downstream partners. Because the underlying substance data model isn't SCIP-specific, it's also positioned to feed a future Digital Product Passport requirement without a separate data migration, whichever way the repeal proposal ultimately lands.

Simplify Your SCIP Submissions, and Prepare for What Comes Next

Regilient helps you collect accurate supply chain data, prepare IUCLID-format dossiers, track submissions against your live BOM, and stay ahead of both Candidate List changes and the regulatory shift toward Digital Product Passports.

Book a compliance strategy call →

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WFD (SCIP)REACHEuropean Union Regulations

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What Is the SCIP Database?

What is the SCIP database and why is it required?
The SCIP database is the EU’s official repository for reporting Substances of Very High Concern (SVHCs) in products under the Waste Framework Directive. It ensures transparency on hazardous substances throughout the product lifecycle and promotes safer waste treatment and circular economy practices
Who needs to submit data to the SCIP database?
Any company placing articles on the EU market, manufacturers, importers, assemblers, or distributors-must submit a SCIP notification if their products contain more than 0.1% w/w of a Candidate List SVHC .
How do I know if my product contains a reportable SVHC for SCIP?
Check your product’s Full Material Declaration (FMD) or BOM against the latest ECHA Candidate List . If any listed SVHC is above 0.1% weight by weight in an article, it requires a SCIP submission.
What information must be included in a SCIP notification?
SCIP submissions must include: Article identification SVHC identification (with concentration range) Safe use instructions Material or complex object structure EU REACH-compliant company information
Is SCIP compliance the same as REACH compliance?
No. While related, SCIP is a separate obligation under the Waste Framework Directive and goes beyond REACH Article 33 by requiring digital submissions to ECHA’s database .
How often do I need to update SCIP submissions?
Any time your product’s composition changes, especially SVHC content—or when new substances are added to the Candidate List , your SCIP dossier must be updated.
How does Acquis help with SCIP database compliance?
Regilient automates the creation and maintenance of SCIP dossiers, validates SVHC data across your BOMs, collects supplier declarations, and ensures your submissions stay up to date as regulations evolve. automates the creation and maintenance of SCIP dossiers, validates SVHC data across your BOMs, collects supplier declarations, and ensures your submissions stay up to date as regulations evolve.
What is the SCIP database?
SCIP (Substances of Concern In articles, as such or in complex objects) is an ECHA-managed database established under the EU Waste Framework Directive, storing information on SVHCs present in articles placed on the EU market.
When did SCIP submission become mandatory?
SCIP submissions have been required since 5 January 2021 for companies manufacturing, importing, assembling, or distributing articles containing SVHCs above the 0.1% w/w threshold in the EU/EEA.
Is the EU actually planning to repeal the SCIP database?
Yes. On 10 December 2025, the European Commission published a formal legislative proposal, COM(2025) 986, to repeal the SCIP notification obligation as part of its Environmental Omnibus package. The proposal has not yet been adopted, and current SCIP obligations remain fully in force.
What happens to my SCIP data if the repeal is adopted?
The proposal doesn't retroactively erase submitted data, and the Waste Framework Directive continues to provide the legal basis for substance and circular economy information more broadly. The Commission expects the Digital Product Passport to eventually take over the function SCIP currently serves.
What format are SCIP dossiers submitted in?
Submissions are made in the IUCLID format, ECHA's standard for chemical data, either through the SCIP-IT portal or via system-to-system integration.
What are the penalties for failing to submit to SCIP?
Penalties vary by Member State. Germany, for example, permits fines of up to €1 million plus potential imprisonment of up to five years for serious breaches; other Member States apply different, generally lighter, administrative penalties.
What's the difference between SCIP and REACH Article 33?
Both are triggered by the same SVHC threshold, but Article 33 is a customer and consumer disclosure duty under REACH, while SCIP is a separate database submission to ECHA supporting waste treatment transparency under the Waste Framework Directive. Meeting one doesn't satisfy the other.
Do non-EU companies need to submit to SCIP?
Only if they're placing the product on the EU market directly. Non-EU companies not placing products on the market themselves aren't required to submit, though they frequently do so voluntarily to support EU-based customers' own compliance.