On October 31, 2019, ECHA published the data format that manufacturers, importers, and distributors will need to follow to submit data into the Substances of Concern in Products (SCIP) database. ECHA is currently developing a prototype system that it expects to have available for public testing in late January next year. The fully functional system for duty holders to start submitting information is expected to be ready in October 2020. The legal obligation to have submitted SVHC information starts in just over a year on January 5, 2021.
ECHA is providing three methods for duty holders to submit their article and substance information:
- Online submission via a web-based user interface;
- Offline using the ECHA IUCLID tool and then submitting manually;
- System to system – a company’s own IT system creates all of the submissions according to the IUCLID data format and then uses a system-to-system portal to submit multiple records into the system.
The same information needs to be provided regardless of which submission method is used. The system-to-system will be most efficient for large organizations with many products containing SVHCs and by solution providers who can afford the custom IT development. The cloud-based approach will be well suited for organizations that need to make only a few submissions and don’t wish to undertake the training needed to use the IUCLID tool.
The ARTICLE XML schema published by ECHA gives us a good indication of the data needed for submission. The schema bundles the information into data groups (see Figure 2) for: Identifiers, Categorization, Characteristics, Safe Use Instructions, Complex Object Components, and Concern Elements. The Concern Element contains information about the SVHC in the article and the type of material/mixture that the SVHC is contained in.
ECHA also revealed that several of the data fields will use picklists provided by ECHA. This means that an exact entry from the list will need to be submitted instead of free text. Data fields using picklists include:
- Primary article identifier (Type) (e.g. EAN, GPC, GTIN, with option for other)
- Other article identifier (Type) (e.g. EAN, GPC, GTIN, with option for other)
- other names (Type) (e.g. brand, model, type with option to specify other)
- Article categories (i.e. CN codes)
- Produced in European Union
- Unit of measure for characteristics
- Candidate List Version
- Concentration range
- Material category
- Additional material characteristics
- Mixture category
- Language of disassembly instructions
There is also a data field to indicate that the Candidate List Substance is no longer present within the article.
The ARTICLE XML schema is included as part of the latest release of the ECHA IUCLID data format (IUCLID 6.4) and is available on the ECHA website. ECHA updates the IUCLID format once a year.