Pitfall in SCIP notifications for retailers

Retailers suppling articles and products to private consumers only may easily miss a possible requirement to register their articles in EU's new SCIP database.

According to information on the webpage of the European Chemicals Agency (ECHA), retailers and other supply chain actors supplying articles directly and exclusively to consumers are not covered by the obligation to provide information to the SCIP database.

However, a closer look at ECHA's guide to Requirements for SCIP Notifications reveals that if you are an importer into the EU and/or producer of an article containing a substance of very high concern (SVHC) in a concentration above 0.1% by weight, you are required to submit information about your article to the SCIP database, even if you are supplying the article directly to consumers only.

The requirements of SCIP notifications
You are required to notify an article in the SCIP database if it contains an SVHC substance on the EU Candidate List in a concentration of more than 0.1% by weight. The requirement has been in force since 5 January 2021. Read more here.

The purpose of the SCIP database is to provide better information on the content of SVHC in articles to consumers and to waste operators in connection with recycling. Since the obligation came into force, ECHA has received more than five million notifications to the SCIP database. ECHA expects to start publishing the data in the coming months.

For more information on SCIP and how to make a notification, please contact:

Anne Rathmann Pedersen
Tel +45 4516 9370