Implementing EU SCIP Reporting

All companies operating within the EU market must comply with SCIP regulations if they supply articles (parts, assemblies, products). This includes manufacturers, importers, and distributors. Articles containing Substances of Very High Concern (SVHCs) in concentrations exceeding 0.1% wight by weight (w/w) fall under SCIP reporting requirements. However, retailers selling directly in the EU market are exempt from these obligations.

Each EU member state has its own statutes governing penalties for SCIP non-compliance. For instance, Germany may impose fines of up to €10,000 per case. This legislation became effective on November 24, 2023. Non-compliance can result in reputational damage leading to loss of market share, heightened scrutiny, and audits, in addition to financial penalties.

To establish a SCIP compliance program within your organization, the following steps are recommended:

Centralized Data Management

Establish a centralized system or acquire software dedicated to managing SCIP-related data. Maintain a comprehensive database of SVHC content within Bills of Materials (BOMs), including parts and/or assemblies, and relevant details. Be sure to regularly update the system to reflect changes in product composition.

Automated Data Collection

Use automation tools to collect necessary information efficiently. Integrate these tools with existing systems (e.g., PLM, ERP, or compliance application) to extract relevant data seamlessly. Don’t forget to minimize manual effort by automating data entry processes.

Collaboration Across Departments

Engage cross-functional teams (e.g., compliance, procurement, product development) in SCIP reporting. Next, ensure seamless communication across the organization to gather accurate data from various sources. Collaborate to identify SVHCs and assess their presence in parts and assemblies.

Supplier Engagement

Work closely with suppliers to obtain SVHC-related information. Encourage suppliers to provide SCIP-relevant data during procurement processes or via their websites. One overlooked key is to establish easy workflow channels for data exchange. In some cases it may be necessary to deploy engineering resources to determine compliance through material-level analysis for items not assessed by suppliers.

Standardized Templates and Workflows

Develop standardized templates for SCIP dossiers. Create workflows guiding employees through the reporting process. ?Always ensure consistency in data collection and submission.

Training and Awareness

Train relevant personnel on SCIP requirements while raising awareness about the importance of accurate reporting. It’s also important to provide guidelines on identifying SVHCs and creating SCIP dossiers.

Regular Audits and Reviews

Conduct periodic audits to verify data accuracy. Next, review SCIP submissions for completeness and correctness. Make sure to address any discrepancies promptly.

Software and Outsourced Service Solutions

Many companies will opt to explore software or middleware solutions designed for SCIP reporting. Evaluate and choose a solution that aligns with your company’s needs, offering features such as data validation, workflow, and management.

It's important to remember that SCIP reporting is an ongoing process. Companies should consider partnering with a qualified compliance vendor and staying informed about updates to the SVHC list. By implementing efficient workflows and leveraging technology, organizations can streamline SCIP compliance and contribute to a more sustainable future.

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About the Author

Bob Caskey leads demand creation at Rumzer. Rumzer’s suite of SaaS modules and professional services makes product environmental compliance simple and affordable so that all manufacturers, regardless of size, can more easily contribute to a cleaner planet and a sustainable global economy.

Rumzer’s great team is on a big mission. To inquire about our product compliance software or to discuss how we can help your organization address your compliance challenges, please email [email protected].