SCIP database submissions extended to the entire EEA including Iceland, Norway, and Liechtenstein

The EU Waste Framework Directive (WFD) provides the legal framework for waste management in the European Union. SCIP is one specific information requirement established under the WFD for articles containing substances on the REACH Candidate List.

For electronics manufacturers, the important distinction is that WFD is the broader waste framework, while SCIP is a specific database notification obligation within that framework.

Understanding that relationship helps compliance teams determine what SCIP requires, which products and articles need assessment, and how product data should be maintained.

What Is the EU Waste Framework Directive?

The Waste Framework Directive, Directive 2008/98/EC, establishes the EU's overall framework for waste management.

It covers broader areas such as:

• Waste prevention
• Waste management
• Resource efficiency
• Waste hierarchy
• Reuse and recycling
• Waste treatment
• Management of hazardous waste

SCIP should therefore not be treated as a separate standalone environmental regulation unrelated to the WFD.

SCIP is a specific information obligation established through the WFD framework to improve information about substances of concern in articles.

What Is the SCIP Database?

SCIP stands for Substances of Concern In articles, as such or in complex objects (Products).

The database is managed by the European Chemicals Agency (ECHA).

Its purpose is to make information about articles containing Candidate List substances available through the product lifecycle, including when products become waste.

The information can therefore support actors involved in:

• Waste treatment
• Dismantling
• Recycling
• Reuse
• Product lifecycle management

ECHA requires suppliers of relevant articles placed on the EU market to provide information to the SCIP database.

How Are WFD and SCIP Connected?

The relationship can be simplified as:

EU Waste Framework Directive

↓

Information requirement for substances of concern in articles

↓

SCIP database

↓

Information available for lifecycle and waste management

The WFD establishes the broader legal context.

SCIP provides the structured information mechanism for relevant articles containing Candidate List substances above 0.1% w/w.

This means that saying a company is "WFD compliant" does not automatically mean that its SCIP obligations have been assessed.

The specific SCIP requirements need to be evaluated separately.

Why Was SCIP Introduced?

SCIP addresses an information gap at the waste stage.

Information about substances contained in products may exist within manufacturing and supply-chain systems, but waste operators may not have access to the same information when products reach end of life.

SCIP is designed to make relevant information available so that waste operators and other actors can better understand substances of concern in articles.

ECHA states that information submitted to SCIP is made publicly available, subject to protections for justified confidential business information.

For electronics manufacturers, this creates a direct connection between product material information and end-of-life information needs.

Who Needs to Submit SCIP Information?

The SCIP notification obligation applies to suppliers of articles placed on the EU market where those articles contain a Candidate List substance above 0.1% w/w.

ECHA identifies relevant supplier categories including:

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

Retailers and other actors supplying articles directly and exclusively to consumers are not covered by the SCIP information obligation.

The obligation has applied since 5 January 2021.

When Does SCIP Apply to an Electronics Product?

The starting point is not simply the finished product.

Manufacturers need to assess the articles within the product and determine whether relevant Candidate List substances are present above 0.1% w/w.

For example:

Finished electronic product

→ PCB assembly

→ Connector

→ Housing

→ Coating

→ Material

→ Candidate List substance

The relevant article or articles need to be assessed within the product structure.

ECHA specifically advises companies to consider articles as such and articles incorporated into complex objects.

What Is an Article Under SCIP?

SCIP uses the concept of an article established under REACH.

Under REACH Article 3(3), an article is an object that is given a special shape, surface or design during production that determines its function to a greater degree than its chemical composition.

For electronics manufacturers, this distinction matters because individual components can remain articles when incorporated into a larger product.

A finished electronic device can therefore contain multiple articles rather than being treated as one single material record.

What Is a Complex Object?

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

This is particularly relevant to electronics.

A product could contain:

Product

→ Assembly

→ Component

→ Article

→ Material

→ Candidate List substance

Articles that retain their relevant characteristics can remain articles when incorporated into a complex object.

This structure is important when preparing SCIP data because the notification can include relevant components containing Candidate List substances.

What Information Does SCIP Require?

ECHA requires information that allows the relevant article to be identified and understood.

This includes information such as:

• Article name
• Article identifiers
• Article category
• Characteristics that distinguish the article
• Candidate List substance
• Substance concentration range
• Substance location
• Material category
• Safe-use information
• Relevant information about components within complex objects

For complex objects, the notification can include the relevant article components and the number of occurrences of linked articles.

The practical implication is important:

SCIP is not simply an SVHC yes/no declaration.

It requires structured product and article information.

Why Is Product Data Important for SCIP?

A SCIP notification is only as reliable as the product information behind it.

For an electronics manufacturer, the underlying data may come from several systems:

• Supplier declarations
• FMD records
• BOMs
• PLM
• ERP
• Product compliance systems
• Engineering records

The compliance workflow needs to connect those sources.

A useful model is:

Supplier

→ Component

→ Material

→ Substance

→ BOM

→ Product

→ SCIP assessment

Without these relationships, a manufacturer may know that an SVHC exists but struggle to determine which products, components or articles are affected.

How Does Supplier Data Support SCIP?

Supplier data is often the starting point for identifying substances in purchased components.

A manufacturer may need to obtain:

• Component identification
• Material information
• Candidate List substance information
• Concentration range
• Substance location
• Supporting evidence
• Relevant article information

The information then needs to be validated and connected to the correct component.

For a practical supplier-data workflow, see Get FMD Data Without Chasing Suppliers for Electronics Manufacturers.

How Does FMD Support SCIP?

Full Material Disclosure can provide a broader material and substance data foundation for product compliance.

The distinction is important:

FMD is product and material data.

SCIP is a regulatory notification requirement.

FMD can help establish relationships between:

Product → Component → Material → Substance

That information can then be assessed against SCIP requirements.

FMD therefore supports the data collection and validation layer, but it does not replace the SCIP notification process.

See Full Material Disclosure: The Complete Guide to Material Data, Standards and Compliance.

What Is the Role of ECHA?

ECHA manages the SCIP database and provides the technical framework for preparing and submitting SCIP notifications.

ECHA provides:

• SCIP information requirements
• IUCLID-based submission format
• Validation rules
• Submission tools
• Guidance
• Referencing mechanisms
• Simplified SCIP Notifications
• System-to-system submission options

The current SCIP format listed by ECHA is version 6.10, April 2026. The format is XML-based and compatible with IUCLID.

Manufacturers using automated workflows should therefore ensure that their implementation remains aligned with ECHA's current format and validation requirements.

Can Previously Submitted SCIP Data Be Reused?

Yes.

ECHA provides mechanisms to reduce duplicate submissions.

The Simplified SCIP Notification (SSN) allows companies to refer to information already successfully submitted to the SCIP database.

Referencing can also allow assemblers to refer to notifications already submitted for articles incorporated into complex objects.

This is particularly useful for electronics manufacturers because the same component may appear across multiple products.

For example:

Connector A

→ Product 1

→ Product 2

→ Product 3

Instead of treating every occurrence as an entirely new data problem, manufacturers can use the relevant referencing mechanisms where applicable.

How Should Manufacturers Prepare for SCIP?

A practical preparation workflow is:

1. Identify products placed on the EU market

Determine which products and articles fall within the manufacturer's role in the supply chain.

2. Map the product structure

Connect:

Product → BOM → Component → Article

3. Identify Candidate List substances

Determine which relevant articles contain Candidate List substances above 0.1% w/w.

4. Collect supplier information

Obtain the substance, material and article information needed for the assessment.

5. Validate the information

Check:

☐ Article identity

☐ Candidate List substance

☐ Concentration range

☐ Substance location

☐ Material category

☐ Product relationship

☐ Supporting evidence

6. Prepare the notification

Structure the information according to the applicable SCIP format.

7. Validate before submission

Check the notification against ECHA's requirements and validation rules.

8. Submit and maintain

Track the notification and maintain the underlying product data when products, suppliers or materials change.

How Should SCIP Data Be Maintained?

SCIP should not be treated as a one-time reporting exercise.

The underlying product information can change because of:

• Supplier changes
• Component substitutions
• Material changes
• BOM revisions
• Product redesigns
• New Candidate List substances
• Changes in supplier declarations

A connected workflow should therefore follow:

Change

→ Affected substance

→ Affected material

→ Affected component

→ Affected BOM

→ Affected product

→ SCIP impact assessment

This allows compliance teams to identify where a change may affect existing SCIP information.

What Is the Difference Between SCIP and REACH?

SCIP and REACH are closely related but separate.

REACH creates several obligations concerning Candidate List substances.

For example, EU and EEA suppliers of articles containing Candidate List substances above 0.1% w/w have communication obligations under REACH Article 33.

REACH also contains a separate notification obligation for certain producers and importers of articles where the applicable conditions are met.

SCIP is the notification obligation established under the Waste Framework Directive.

The same underlying product and substance information can support both processes, but one does not replace the other.

For a detailed comparison, see SCIP vs REACH: Key Compliance Differences for Electronics Manufacturers.

How Should Electronics Manufacturers Connect WFD and SCIP Data?

The most useful approach is to connect the broader regulatory requirement with the product data underneath it.

A practical structure is:

Regulation

↓

Requirement

↓

Product

↓

BOM

↓

Article

↓

Material

↓

Substance

↓

Evidence

↓

SCIP notification

This makes it easier to determine why a particular article needs to be reported and which underlying evidence supports the notification.

It also creates a reusable foundation for other product compliance processes.

Common WFD and SCIP Mistakes

Treating WFD and SCIP as the same thing

The WFD is the broader waste framework. SCIP is a specific information requirement within that framework.

Treating SCIP as a general hazardous-substance database

SCIP specifically concerns articles containing Candidate List substances above 0.1% w/w within the applicable obligation.

Assessing only the finished product

SCIP requires article-level information. The manufacturer needs visibility into relevant components and articles within complex objects.

Treating supplier declarations as submission-ready data

Supplier information needs to be validated and connected to the correct article and product.

Separating SCIP data from BOM data

Without product relationships, it becomes difficult to identify which finished products are affected when a component changes.

Rebuilding the same information for every product

ECHA provides mechanisms for referencing previously submitted SCIP information, reducing unnecessary duplication where applicable.

Treating SCIP as permanently complete after submission

Product and regulatory data can change. The underlying compliance process needs a mechanism for review and maintenance.

How Can Regilient Support WFD and SCIP Compliance?

Regilient can help manufacturers connect product compliance data with regulatory requirements through a structured workflow.

Relevant capabilities include:

• Supplier data collection
• Material and substance data management
• BOM-level compliance assessment
• Regulatory status mapping
• Evidence management
• SCIP workflow support
• Product and component relationships
• Compliance change tracking
• Reusable compliance data

The objective is not to treat SCIP as an isolated reporting task.

It is to connect supplier data, product structure, material information and regulatory requirements so that compliance teams can maintain reliable information throughout the product lifecycle.

For broader environmental compliance capabilities, see Environmental Compliance Software for Electronics Manufacturers.

Building a Reliable WFD and SCIP Compliance Workflow

The WFD provides the broader waste-management framework.

SCIP provides a specific mechanism for making information about relevant substances of concern in articles available through the product lifecycle.

For electronics manufacturers, the practical workflow is:

Identify → Collect → Validate → Connect → Assess → Prepare → Submit → Monitor → Update

The strongest SCIP process begins with reliable product and supplier data rather than at the submission screen.

When articles, materials, substances, BOMs and supplier evidence are connected, manufacturers can build a more traceable and maintainable approach to WFD and SCIP compliance.