In late January, the European Chemical Agency (ECHA) posted statistics on notifications submitted into the EU SCIP database since it became operational. This essentially covers the first year since the legal obligation for manufacturers, importers, and distributors to notify products with REACH Candidate List SVHCs took effect on January 6, 2021.
A few notable statistics that they mention are:
- Seven million searchable articles in the database
- Note: Given that one submission may represent a family of similar products (using product grouping), the number of searchable articles could represent many times that number in total products in the database.
- Over 7,000 companies have successfully submitted notifications of products with SVHCs.
- Of the total number of submissions, 77% were submitted using the system-to-system service, 22% using IUCLID application, and 1% using the IUCLID cloud services.
In a separate bulletin to members of the SCIP IT User Group, ECHA described their plan for the next couple years. The next major release to the IUCLID format (including SCIP elements) has been shifted from October 2022 to April 2023. This means that the SCIP data requirements and functionality should remain stable over the upcoming 14 months.
ECHA also highlighted a couple of submission anomalies that they are seeing.
Multiple SSN notifications using the same SCIP number
ECHA is seeing a number of occurrences when a company attempts multiple SSN (simplified SCIP notifications) submission requests using the same SCIP number. SSN are typically made by importers and distributers using the SCIP number provided by the upstream manufacturer. The situation described by ECHA could easy occur in the following business scenario:
- if a SCIP number covers multiple products from the manufacturer (ECHA has recommended that manufacturers do this to improve efficiency)
- the importer then tries to make a separate SSN for each individual product (using the same SCIP number). The first SSN will work, but the second and subsequent SSN attempts using the same SCIP number will fail.
- EU Importers and distributers may not be aware that their SSN submissions need to exactly cover the same products that are included in the original dossier. They should not try to make individual submissions for each product.
Manufacturers who receive feedback from importers that their SCIP numbers are causing errors, should keep this in mind and ask the importer to make sure they do not submit the same SCIP number more than once.
To be proactive when providing SCIP numbers to importers, it may be helpful to clearly indicate in your communications the products that are grouped together under a common SCIP number.
Excessive SCIP updates
The second anomaly reported by ECHA are cases when rapid update submissions are made to the same article over a very short period of time (less than a minute). This may be due to a solution provider’s software bug.