Table of Contents
- REACH vs SCIP: What Is the Difference?
- What Does REACH Require for Articles?
- What Does SCIP Require?
- Why Are REACH and SCIP Often Confused?
- Do REACH and SCIP Use the Same 0.1% Threshold?
- What Information Does SCIP Need?
- Why Is Article-Level Data Important?
- How Does Supplier Data Support Both REACH and SCIP?
- Can FMD Support REACH and SCIP?
- What Is the Difference Between REACH Communication and SCIP Notification?
- REACH Article 33
- SCIP
- Is SCIP a Replacement for REACH?
- Does a SCIP Submission Automatically Satisfy REACH?
- How Should Electronics Manufacturers Connect REACH and SCIP Data?
- How Should Manufacturers Monitor Changes?
- What About SCIP Data Already Submitted?
- How Is SCIP Submitted?
- What Should Electronics Manufacturers Validate?
- Product and article data
- Substance data
- Evidence
- Regulatory action
- REACH vs SCIP: A Practical Example
- Common Mistakes When Managing REACH and SCIP
- Treating SCIP as a REACH replacement
- Treating a supplier declaration as a SCIP submission
- Maintaining only finished-product data
- Separating compliance data from the BOM
- Rebuilding supplier data for every regulation
- Treating compliance as a one-time exercise
- How Regilient Can Support REACH and SCIP Management
- Building One Data Foundation for REACH and SCIP
SCIP and REACH are closely connected, but they are not the same compliance obligation.
Both can involve articles containing substances on the REACH Candidate List above 0.1% w/w. However, they operate under different legal frameworks and serve different purposes.
For electronics manufacturers, the practical challenge is understanding which information needs to be communicated to customers, which information needs to be notified to ECHA, and how the same product and material data can support both processes.
This guide explains the relationship between REACH and SCIP and how manufacturers can manage the two requirements without creating separate, disconnected data processes.
REACH vs SCIP: What Is the Difference?
REACH | SCIP | |
|---|---|---|
Legal framework | EU REACH Regulation | EU Waste Framework Directive |
Main focus | Chemicals and substances throughout their lifecycle | Substances of concern in articles and complex objects, including at the waste stage |
Key article obligation | Communication under Article 33 | Notification to ECHA under the WFD |
Relevant substance threshold for article communication/SCIP | Candidate List substance above 0.1% w/w | Candidate List substance above 0.1% w/w |
Primary information flow | Supplier to recipient/customer | Supplier to ECHA and SCIP database |
Typical product data | Article, SVHC and safe-use information | Article, SVHC, concentration range, location, material information and relevant safe-use information |
Main operational concern | Communicating information through the supply chain | Making relevant article information available through the product lifecycle, including the waste stage |
The important point is that SCIP does not replace REACH.
A manufacturer may need to fulfil REACH obligations and SCIP obligations for the same article, but the information is used for different purposes.
What Does REACH Require for Articles?
REACH Article 33 addresses communication about Candidate List substances in articles.
Where an article contains a Candidate List substance above 0.1% w/w, an EU or EEA supplier of the article has to provide sufficient information to allow safe use of the article to its customers.
That information must include, at a minimum, the name of the substance.
Consumers can also request information about Candidate List substances in an article. ECHA states that the information must be provided within 45 days of receiving the request.
For manufacturers, this means REACH compliance is not simply about maintaining a substance list.
The manufacturer needs enough reliable product and article information to communicate the relevant information when required.
What Does SCIP Require?
SCIP is established under the Waste Framework Directive.
Companies supplying articles containing Candidate List substances above 0.1% w/w and placing those articles on the EU market have to submit information to ECHA for the SCIP database when they fall within the covered supplier categories.
ECHA identifies EU producers and assemblers, EU importers, EU distributors of articles and other supply-chain actors placing articles on the market among the suppliers required to provide information to ECHA.
The information is intended to remain available throughout the lifecycle of products and materials, including the waste stage.
This gives SCIP a different operational purpose from REACH Article 33 communication.
Why Are REACH and SCIP Often Confused?
The confusion comes from the fact that both processes can start with the same underlying product information.
For example:
Supplier data
→ Component
→ Material
→ Candidate List substance
→ Concentration
→ Article
→ Finished product
That information may then support:
REACH
→ Supply-chain communication
and
SCIP
→ Notification to ECHA
The data overlaps, but the compliance action is different.
This is why manufacturers should avoid treating REACH and SCIP as two completely separate data-collection projects.
Do REACH and SCIP Use the Same 0.1% Threshold?
For the relevant article obligations, both REACH Article 33 communication and the SCIP notification obligation use the 0.1% w/w threshold for Candidate List substances in articles.
However, the existence of the same threshold does not mean that all REACH and SCIP requirements are identical.
REACH also contains other obligations, including a separate Article 7(2) notification requirement for certain producers and importers of articles.
Under that provision, an EU or EEA producer or importer may have to notify ECHA where the relevant Candidate List substance is above 0.1% w/w and the total quantity exceeds one tonne per producer or importer per year, subject to the conditions and exemptions set out by REACH.
Therefore, manufacturers should assess the specific REACH obligation rather than assuming that SCIP automatically represents their entire REACH compliance position.
What Information Does SCIP Need?
SCIP requires more structured information about the article.
ECHA identifies information including:
- Article identification
- Candidate List substance identification
- Concentration range
- Location of the substance in the article
- Material category or relevant mixture category
- Information needed for safe use, particularly where relevant to waste management
For complex objects, the notification can also represent the relevant articles containing Candidate List substances and their relationships within the complex object.
This makes the underlying product structure particularly important for electronics manufacturers.
Why Is Article-Level Data Important?
A finished electronic product can contain hundreds or thousands of individual components.
A single product-level statement such as:
"Contains no restricted substances"
is not enough to build a reliable SCIP data structure.
Manufacturers need to understand which article contains the Candidate List substance and where that article sits within the product.
For example:
Finished product
→ Control board
→ Connector
→ Housing
→ Coating
→ Material
→ Candidate List substance
The compliance relationship needs to remain traceable back to the relevant article.
ECHA's SCIP requirements are therefore structured around articles and complex objects rather than treating the finished product as a single material record.
How Does Supplier Data Support Both REACH and SCIP?
Supplier information is one of the most important inputs for both workflows.
For an electronics manufacturer, supplier data may include:
- Component identification
- Material composition
- Candidate List substance information
- Concentration range
- Substance location
- Material category
- Supporting declaration or evidence
- Relevant product or part references
The same validated information can then support different compliance processes.
For example:
Supplier declaration
→ Validate
→ Component
→ Material
→ Substance
→ BOM
→ Product
From there:
REACH → Communication
SCIP → Notification
This approach avoids repeatedly asking suppliers for essentially the same underlying information.
For a more detailed supplier-data workflow, see Get FMD Data Without Chasing Suppliers for Electronics Manufacturers.
Can FMD Support REACH and SCIP?
Yes, but FMD should be treated as an underlying material and substance data layer, not as a replacement for either regulatory requirement.
Full Material Disclosure can provide information about:
- Materials
- Substances
- Components
- Concentrations
- Product relationships
- Supplier information
That information can then be assessed against individual regulatory requirements.
For SCIP, FMD can help manufacturers identify the relevant substance, material and article relationships.
For REACH, the same information can support Candidate List assessments and supply-chain communication.
The important distinction is:
FMD = underlying product and material data
REACH = regulatory obligations
SCIP = regulatory notification under the Waste Framework Directive
See Full Material Disclosure: The Complete Guide to Material Data, Standards and Compliance.
What Is the Difference Between REACH Communication and SCIP Notification?
This is one of the most important distinctions for compliance teams.
REACH Article 33
The information primarily moves through the supply chain.
Supplier → Customer / Recipient
The objective is to provide enough information for safe use of the article.
SCIP
The relevant information is submitted to ECHA.
Supplier → ECHA → SCIP database
The objective is to make information about substances of concern in articles available through the product lifecycle, including at the waste stage.
The same underlying data can support both workflows, but the recipient and purpose are different.
Is SCIP a Replacement for REACH?
No.
SCIP does not replace REACH Article 33 communication.
A manufacturer should not assume that submitting a SCIP notification means it has completed all relevant REACH obligations.
Likewise, providing an Article 33 communication to a customer does not mean that the manufacturer has completed its SCIP notification obligation.
The two processes should therefore be managed as related but distinct compliance activities.
Does a SCIP Submission Automatically Satisfy REACH?
No.
A SCIP submission should not be treated as a substitute for the information that needs to be communicated under REACH Article 33.
The compliance team should separately assess:
☐ Does the article contain a Candidate List substance above 0.1% w/w?
☐ Does REACH Article 33 communication apply?
☐ Is sufficient safe-use information available?
☐ Does the article fall within the SCIP notification obligation?
☐ Is the information required by SCIP available?
☐ Has the SCIP information been prepared and validated?
☐ Are the relevant product and article relationships documented?
This prevents the common mistake of treating one regulatory workflow as proof that the other has been completed.
How Should Electronics Manufacturers Connect REACH and SCIP Data?
A connected product compliance data model can reduce duplication.
A practical structure is:
Supplier
↓
Component
↓
Material
↓
Substance
↓
BOM
↓
Finished Product
↓
Regulatory Assessment
↓
REACH / SCIP
This structure allows manufacturers to reuse validated information while keeping the regulatory decisions separate.
For example, if a supplier updates the material composition of a connector, the manufacturer should be able to identify:
- Which component changed
- Which material changed
- Which substance is affected
- Which products use the component
- Whether REACH communication needs to be reviewed
- Whether the SCIP notification is affected
- Which records need to be updated
That is much more scalable than maintaining separate spreadsheets for every regulation.
How Should Manufacturers Monitor Changes?
Candidate List changes can affect both REACH and SCIP assessments.
However, the response should be based on the specific regulatory obligation and the affected article or product.
A robust process should therefore connect regulatory monitoring with product data.
Regulatory change
→ Identify affected substance
→ Identify affected materials
→ Identify affected components
→ Identify affected BOMs
→ Identify affected products
→ Review REACH impact
→ Review SCIP impact
→ Update relevant records
This is where connected compliance data becomes more valuable than a static declaration database.
What About SCIP Data Already Submitted?
ECHA provides mechanisms for referring to SCIP data that has already been submitted.
The Simplified SCIP Notification and referencing mechanisms can reduce duplicate data preparation in applicable cases.
For manufacturers with large product portfolios, this can be important because the same article may appear in multiple products or complex objects.
The objective should be to create reusable, validated article data rather than repeatedly rebuilding the same information.
How Is SCIP Submitted?
ECHA's SCIP format structures the information required for articles containing Candidate List substances above 0.1% w/w.
The current ECHA page lists SCIP format version 6.10, April 2026. The format is XML-based and compatible with IUCLID.
ECHA provides tools and support materials for preparing and submitting SCIP notifications, including information requirements, validation rules and mechanisms for referring to previously submitted SCIP data.
For manufacturers, the important point is that submission is the final stage of the workflow.
The quality of the submission depends on the quality of the product and supplier data underneath it.
What Should Electronics Manufacturers Validate?
Before relying on a REACH or SCIP record, compliance teams should validate the underlying data.
Product and article data
☐ Correct product identifier
☐ Correct component or article identifier
☐ Correct BOM relationship
☐ Correct supplier relationship
Substance data
☐ Correct Candidate List substance
☐ Current regulatory status
☐ Concentration information
☐ Substance location
☐ Material information
Evidence
☐ Supplier declaration available
☐ Supporting information retained
☐ Data linked to the relevant component
☐ Data freshness assessed
Regulatory action
☐ REACH Article 33 requirement assessed
☐ Other applicable REACH obligations assessed
☐ SCIP obligation assessed
☐ SCIP information prepared where required
☐ Existing SCIP data considered for reuse
REACH vs SCIP: A Practical Example
Consider an electronic controller containing a connector supplied by a third-party manufacturer.
The supplier provides material information showing that a Candidate List substance is present above 0.1% w/w in the connector.
The manufacturer can then establish:
Supplier
→ Connector
→ Material
→ Candidate List substance
→ Concentration
→ Controller BOM
→ Finished controller
The information can support a REACH Article 33 communication where applicable.
The same underlying article and substance information can also support the manufacturer's SCIP notification where the SCIP obligation applies.
The two actions remain separate even though they originate from the same product data.
Common Mistakes When Managing REACH and SCIP
Treating SCIP as a REACH replacement
SCIP does not replace REACH obligations.
Treating a supplier declaration as a SCIP submission
A supplier declaration provides information. It does not automatically constitute the manufacturer's SCIP notification.
Maintaining only finished-product data
SCIP requires article-level information. Product-level records may not provide enough detail.
Separating compliance data from the BOM
When regulatory information cannot be connected to components and products, change management becomes difficult.
Rebuilding supplier data for every regulation
The same material and substance information can often support multiple compliance workflows.
Treating compliance as a one-time exercise
Supplier changes, BOM changes and regulatory changes can affect existing assessments.
How Regilient Can Support REACH and SCIP Management
Regilient can help manufacturers connect supplier information, material data, BOMs and regulatory assessments within a common product compliance workflow.
Relevant capabilities include:
- Supplier data collection and validation
- Material and substance data management
- BOM-level compliance assessment
- Regulatory status mapping
- Evidence management
- SCIP workflow support
- Product-level compliance tracking
- Change impact assessment
- Reuse of validated compliance information
The objective is not to merge REACH and SCIP into one obligation.
It is to maintain a shared, reliable product data foundation that can support the different regulatory actions required for the same products.
For a broader view of environmental compliance workflows, see Environmental Compliance Software for Electronics Manufacturers.
Building One Data Foundation for REACH and SCIP
REACH and SCIP should not be treated as interchangeable requirements.
They are better understood as two regulatory workflows that can draw from the same validated product data.
The practical model is:
Supplier Data → Material → Substance → Component → BOM → Product → Regulatory Assessment
From that foundation:
REACH → Communicate
SCIP → Notify
This approach gives electronics manufacturers a more sustainable way to manage compliance as products, suppliers, BOMs and regulatory requirements change.