SCIP database: who must notify ECHA, and what a seller outside the EU gives its importer

SCIP stands for Substances of Concern In articles as such or in complex objects (Products). It is a public database that ECHA, the European Chemicals Agency, keeps under the Waste Framework Directive (Art. 9(2)Directive 2008/98/EC, Waste Framework DirectiveArticle 9, paragraph 2Click opens the article on EUR-Lex. of Directive 2008/98/EC). It holds one kind of fact: which articles on the EU market contain a substance from the REACH Candidate List above 0.1% by weight, where, and how to handle the article safely once it becomes waste. Waste treatment operators can read it, and consumers on request.

Who must submit a SCIP notification

The Waste Framework Directive tells each EU country to ensure that “any supplier of an article” as REACH defines it gives ECHA the information owed under REACH Art. 33(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 33, paragraph 1Click opens the article on EUR-Lex., from 5 January 2021 (Art. 9(1)(i)Directive 2008/98/EC, Waste Framework DirectiveArticle 9, paragraph 1, point (i)Click opens the article on EUR-Lex. of Directive 2008/98/EC). REACH defines the supplier of an article as any producer or importer of an article, distributor or other actor in the supply chain placing an article on the market (Art. 3(33)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 33Click opens the article on EUR-Lex.). ECHA turns that into a list of who files.

ECHA’s words: “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.” Its requirements document adds that retailers who are importers or producers are covered (ECHA, Requirements for SCIP notifications, archive copy, section 1.2). The reason is in REACH: the SCIP information is the Art. 33(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 33, paragraph 1Click opens the article on EUR-Lex. information, which is owed to a “recipient of an article”, and a recipient is an industrial or professional user or a distributor, not a consumer (Art. 3(35)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 35Click opens the article on EUR-Lex.).

What triggers it. An article placed on the EU market that holds a Candidate List substance above 0.1% by weight. An article is an object whose shape, surface or design decides its function more than its chemical composition (Art. 3(3)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 3Click opens the article on EUR-Lex.). The 0.1% is counted per article inside a product, as set out in the SVHC guide. A product made of several articles is a complex object, and its notification covers each article that holds the substance. Spare parts that are supplied are covered. A repaired article that is not supplied again is not.

When. From 5 January 2021. When a substance is added to the Candidate List later, the supplier files a notification, or updates one, at its next supply or import of the article after the listing. An article placed on the market before 5 January 2021 and not placed on it again after that date does not need one (ECHA, Requirements for SCIP notifications, sections 1.3 and 1.4).

The Commission has proposed to end it. The duty is in force today. On 10 December 2025 the Commission proposed to limit it to the time until the amending Directive enters into force, and to leave ECHA to keep the data already submitted (Art. 1(2) of COM(2025) 986 final). It is a proposal, not law. National texts such as § 16f ChemG and article L. 521-5, III of the French Environment Code apply until each country amends them, and the proposal gives EU countries 24 months to transpose it.

It adds to REACH, it does not replace it. The duty to pass the information to business buyers and to answer a consumer within 45 days stays (Art. 33(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 33, paragraph 1Click opens the article on EUR-Lex., Art. 33(2)Regulation (EC) No 1907/2006, REACH (chemicals)Article 33, paragraph 2Click opens the article on EUR-Lex.). So does the ECHA notification of substances in articles, for a producer or importer whose articles hold the substance above 0.1% and above one tonne a year (Art. 7(2)Regulation (EC) No 1907/2006, REACH (chemicals)Article 7, paragraph 2Click opens the article on EUR-Lex.). The REACH compliance guide lays the three side by side.

A seller outside the EU does not file, its EU importer does

REACH puts import duties on an “importer”, a person “established within the Community who is responsible for import” (Art. 3(11)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 11Click opens the article on EUR-Lex.). Import is the physical introduction into the EU customs territory, and it counts as placing on the market (Art. 3(10)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 10Click opens the article on EUR-Lex., Art. 3(12)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 12Click opens the article on EUR-Lex.). A business outside the EU is not established in the EU, so it cannot be that importer.

ECHA states the SCIP duty in the same terms: “EU suppliers of articles containing substances on the Candidate List in a concentration above 0.1% w/w when placing them on the EU market have to submit information on these articles to ECHA” (ECHA, Candidate List obligations, archive copy). It adds that the articles “can be produced in the EU or imported from non-EU countries” (ECHA, Understanding WFD, archive copy). An article made outside the EU is notified, and the EU importer is the one who notifies it.

The importer is also the first actor that must collect the information, because it owes it both down the chain under Art. 33(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 33, paragraph 1Click opens the article on EUR-Lex. and to ECHA (ECHA, Tools to refer to SCIP data, archive copy, chapters 1 and 2). ECHA quotes its own guidance that the duty applies “regardless of whether or not the supplier is aware of the presence of the substances”. That is why an importer asks you for a statement per article: without it, it cannot name the substance or its concentration range. The responsibility for the quality and accuracy of the data stays with the importer that files (ECHA, Requirements for SCIP notifications, section 2.4).

For the full map of who counts as the importer, see the importer of record guide.

What a SCIP notification contains

ECHA asks for three things: the identification of the article, the name, concentration range and location of each Candidate List substance in it, and the information needed to use the article safely, notably to manage it once it becomes waste (ECHA, suppliers of articles, archive copy). The fields, from ECHA’s requirements document:

The notification is a dossier in ECHA’s IUCLID format, sent through the ECHA Submission Portal after creating an ECHA account for the company, or sent by a company’s own systems through a system-to-system link (ECHA, How to prepare and submit a SCIP notification, archive copy). On success ECHA returns a SCIP number for the notification.

Grouping. Articles that are identical, or nearly so, can be grouped in one notification, as long as each subgroup stays identifiable by brand, model or catalogue number. ECHA discourages a notification for a complex object of more than 1,000 components, and recommends the fewest layers that still show where the substance sits (ECHA, Key tips for successful SCIP notifications, archive copy).

Who can read it. ECHA publishes the information as received. It protects confidential business information where justified, and the data that would link actors in one supply chain is not published. ECHA runs only the programmed validation of the portal and no quality check of its own (ECHA, Requirements for SCIP notifications, section 2.4). Waste treatment operators have access, and consumers on request (Art. 9(2)Directive 2008/98/EC, Waste Framework DirectiveArticle 9, paragraph 2Click opens the article on EUR-Lex. of Directive 2008/98/EC). The public search is ECHA’s SCIP database.

The simplified SCIP notification and referencing let a buyer reuse a notification

Both are voluntary tools. They exist so that a company down the chain does not file the same data a second time (ECHA, Tools to refer to SCIP data, archive copy, chapters 1 to 3).

The SCIP number reaches the buyer only if the supplier passes it on. ECHA suggests sending it with the Art. 33(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 33, paragraph 1Click opens the article on EUR-Lex. information, and calls that voluntary. When the original submitter updates its notification, the notifications that refer to it update too. Neither tool works for goods that no one has notified yet. The duty starts with the first supplier in the chain, a producer or an importer, and for goods made outside the EU that is the importer: it files the full notification, and its customers then refer to it (ECHA, Requirements for SCIP notifications, section 1.2).

How national transposition differs

A directive binds the EU countries, not the companies. Art. 9(1)(i)Directive 2008/98/EC, Waste Framework DirectiveArticle 9, paragraph 1, point (i)Click opens the article on EUR-Lex. tells them to ensure the supplier duty, and each one writes it into its own law and enforces it. ECHA says so about its own guidance: the text of the Directive is the only authentic legal reference, and EU countries enforce the duty and may advise companies (ECHA, Requirements for SCIP notifications, disclaimer and section 3.1.5). The penalties are also each EU country’s, and must be “effective, proportionate and dissuasive” (Art. 36(2)Directive 2008/98/EC, Waste Framework DirectiveArticle 36, paragraph 2Click opens the article on EUR-Lex. of Directive 2008/98/EC). Two national texts, side by side:

Three differences show in practice.

• Timing. ECHA reads the duty as met before the article is placed on the market: successful submission “is the basic requirement before placing on the EU market” an article with a Candidate List substance. German law words it as “without undue delay after” placing. French law sets no timing beyond the start date.
• Grouping. ECHA recommends its own grouping criteria, but each EU country decides whether to allow more far-reaching grouping, such as the “representative article approach” for very complex or customised products. ECHA does not recommend that approach.
• Penalty. Germany makes a missing, wrong, incomplete or late notification an administrative offence when done intentionally or through negligence, with a fine of up to €10,000, or €5,000 if negligent, and more where needed to take away the profit made (§ 26 ChemG, paragraph 1 no. 6a and paragraph 3; § 17 OWiG, paragraphs 2 and 4). Each other EU country sets its own sum under Art. 36(2)Directive 2008/98/EC, Waste Framework DirectiveArticle 36, paragraph 2Click opens the article on EUR-Lex..

Both national texts name any supplier. Neither repeats ECHA’s exclusion of retailers that supply only consumers.

What happens if you do nothing

Without your statement, the EU importer cannot name the substance or its concentration range, and it holds the duty to file. ECHA calls a successful submission the basic requirement before the article is placed on the market, and it publishes what is filed as received, with no quality check beyond the portal’s programmed validation (ECHA, Requirements for SCIP notifications, section 2.4). The penalties are each EU country’s: in Germany a fine of up to €10,000 (€5,000 if negligent, more to take away the profit) for a missing, wrong, incomplete or late notification (§ 26 ChemG; § 17 OWiG), and elsewhere what that country’s law sets (Art. 36(2)Directive 2008/98/EC, Waste Framework DirectiveArticle 36, paragraph 2Click opens the article on EUR-Lex. of Directive 2008/98/EC).

What you can skip

What the law leaves open

• Who files for a parcel sent from outside the EU straight to a consumer. Art. 3(11)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 11Click opens the article on EUR-Lex. requires the importer to be in the EU, and ECHA names EU suppliers. No text says who files when no EU business stands in the chain. Meanwhile, keep the statement per article and answer any consumer who asks within 45 days (Art. 33(2)Regulation (EC) No 1907/2006, REACH (chemicals)Article 33, paragraph 2Click opens the article on EUR-Lex.).
• Whether an importer with an only representative still files SCIP itself. REACH lets a manufacturer outside the EU appoint an only representative to carry the importer duties (Art. 8(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 8, paragraph 1Click opens the article on EUR-Lex., Art. 8(2)Regulation (EC) No 1907/2006, REACH (chemicals)Article 8, paragraph 2Click opens the article on EUR-Lex.), and treats the importers it supplies as downstream users “for the purposes of this Regulation” (Art. 8(3)Regulation (EC) No 1907/2006, REACH (chemicals)Article 8, paragraph 3Click opens the article on EUR-Lex.). The SCIP duty comes from a Directive, and ECHA’s SCIP pages describe no only-representative route. Meanwhile, ECHA’s list names EU importers.
• Whether national law reaches a retailer that supplies only consumers. ECHA excludes it and cites the European Commission’s 2019 non-paper on the Directive. The French and German texts say “any supplier” and do not repeat the exclusion. Meanwhile, such a retailer that is also the importer files.