SCIP notification: how to notify your articles and keep the dossier up to date over time

In brief

• SCIP refers to both an obligation and a database: any supplier of an article containing a substance of very high concern (SVHC) above 0.1% w/w must submit this information to ECHA, regardless of tonnage.
• The SCIP notification does not replace the information required under Article 33 (direct communication to the customer), the Article 7.2 notification (above 1 t/year of substance), or the French consumer information required by Article L. 541-9-1 of the French Environmental Code (AGEC law).
• The dossier is built from supplier data, but at the right level of breakdown: that of the article, not that of the commercial reference.
• A notification is never fixed: it is updated with each addition to the Candidate List, each change in composition and each new reference.
• This page sets out the exact content of a dossier, the 5-step method for compiling it, common errors, the update procedure and a 10-point checklist.

1. SCIP: a short, quotable definition

SCIP (Substances of Concern In articles as such or in complex objects (Products)) is the ECHA database that records substances of very high concern present in articles placed on the European Union market above 0.1% weight by weight, so that waste operators and consumers can know about their presence and location. The obligation to supply it derives from Article 9(1)(i) of the amended Waste Framework Directive 2008/98/EC, applicable since 5 January 2021. In France, it is transposed in paragraph III of Article L. 521-5 of the French Environmental Code (Ordinance No. 2020-920 of 29 July 2020). The terms "SCIP declaration" and "SCIP notification" are used interchangeably to refer to the submission of a dossier to the ECHA SCIP database.

Three practical consequences follow:

• SCIP is an end-of-life traceability tool, not a product compliance register.
• The data expected is not only "which substance", but where it is located in the article, to enable safe dismantling and treatment.
• ECHA publishes the data as submitted and does not validate its quality: the reliability of the dossier remains the responsibility of the submitting company.

2. Who must submit a SCIP notification and from what threshold

The obligation applies to any supplier of an article placed on the European Union market: manufacturer, importer, assembler, distributor. Three criteria are enough to trigger the SCIP notification: The responsibilities of the manufacturer and the importer are detailed in our supplier REACH guide.

1. An article within the meaning of Article 3(3) of Regulation (EC) No 1907/2006: an object whose shape, surface or design determines its function to a greater degree than its chemical composition.
2. A substance on the Candidate List (SVHC), identified by its reference version - 253 entries since 4 February 2026, a list revised twice a year.
3. A concentration strictly above 0.1% weight by weight in that article, assessed article by article, never on the mass of the finished product.

The 1 t/year tonnage threshold does not apply to SCIP: an article sold in a few dozen units per year is still in scope. This threshold only concerns the Article 7.2 notification.

The cases Regulatory teams most often have to decide

• Complex object: the assembly is itself an article, but it contains other articles. The notification covers the complex object and the components concerned, structured as a tree.
• Packaging: cartons, bags and crates are separate articles and must be assessed as such if they contain an SVHC above the threshold.
• Supplier already notifying: when a purchased article has already been notified, its SCIP number can be used. The tools provided by ECHA (simplified SCIP notification for an unchanged article, referencing for an incorporated component) reduce the workload, but do not transfer the responsibility of the operator placing the article on the market.

3. The four obligations that apply cumulatively: Article 33, Article 7.2, SCIP, AGEC L. 541-9-1

This is the point most poorly handled in dossiers: four distinct obligations are often treated as one. The table below serves as a common reference between Regulatory, Quality, Purchasing and CSR teams.

Three useful readings:

• The same article may require three deliverables: written information to the industrial customer, a dossier in the ECHA SCIP database, and a consumer statement under the AGEC law.
• The channel is not the same: SCIP feeds a public database; Article 33 is direct communication; AGEC addresses French consumers at the time of purchase.
• None exempts from the others. A submitted SCIP dossier does not count as Article 33 information, and a supplier attestation does not count as a notification.

4. What a SCIP notification contains

A SCIP dossier is not a flat form: it is a tree of article nodes. The root node describes the product placed on the market; the child nodes describe the components affected by an SVHC. Five blocks of information must be completed.

4.1 Article identity

Article name, brand or model, primary identifier (EAN, GTIN, catalogue reference, part number), other identifiers, and descriptive characteristics: photo, dimensions, colour, weight. Methodological point: an internal reference that a waste operator cannot understand makes the dossier unusable in practice.

4.2 Article node and structure of the complex object

Number of units making up the object, function of each component, and explicit linking of the components concerned to the parent node. It is this structure that allows the recycler to know which part to dismantle.

4.3 SVHC and concentration

Name of the substance as it appears on the Candidate List, concentration range (above 0.1% and up to 100%), material category (for example according to the EuPCS system), and, where applicable, additional material characteristics.

4.4 Use category and customs classification

The article category (CN code / TARIC code and description) is a structuring field of the dossier: it determines searches in the database and sorting by treatment channels. An indication of production in Europe is added where relevant.

4.5 Handling and safe use information

Instructions for safe use throughout the life cycle, and dismantling instructions where end-of-life management requires it. Two errors to avoid: placing the location of the substance in the instructions field (it belongs in the substance block), and completing both instructions and the "substance identification is sufficient" option. They differ from identified uses and exposure scenarios, which concern substances and mixtures used in the workshop.

5. Compiling the SCIP dossier from supplier data: the 5-step method

Step 1 - Map the articles actually placed on the market

Article database: reference, description, mass, CN/TARIC code, supplier, import status, destination markets. Without the mass, the 0.1% threshold cannot be calculated; without the import status, responsibility is wrongly assigned. The calculation of the 0.1% threshold per article requires this mass.

Step 2 - Freeze the version of the Candidate List

Each campaign is based on a dated version ("253 entries, version of 4 February 2026"). Supplier declarations are linked to this version, which determines what will need to be followed up at the next revision.

Step 3 - Collect data at node level, not order level

The supplier questionnaire must request, for each article: identification and mass, name of the SVHC with CAS and EC numbers, concentration in % w/w in the article, a usable concentration range, material category, safe use and dismantling instructions, list version used, date and signatory. A questionnaire per commercial reference never produces a usable SCIP dossier. For an incorporated mixture, cross-check this data against the composition declared in section 3 of the SDS.

Step 4 - Build the tree and decide on the submission method

Group totally identical articles (one notification is enough), then near-identical articles - same function, same name, same category, same SVHC, same material, same instructions. For components already notified by a supplier, choose between simplified notification and referencing. The dossier is prepared in IUCLID (Cloud or local version) or via a system-to-system connection for large volumes.

Step 5 - Submit, archive and schedule the review

Submission via the ECHA Submission portal, retention of the SCIP number and the dossier export, transmission of the number to professional customers as an additional reference, and entry in the review calendar. Submitted notifications cannot be deleted: updating is the only means of correction.

6. Common errors in SCIP notifications

1. Notifying the finished product as a single article. The dossier passes validation but does not make it possible to identify the part to dismantle: it loses its purpose.
2. Confusing the SCIP dossier with proof of REACH compliance. A REACH certificate from a supplier, an ISO certificate or a declaration of conformity does not prove that an SVHC has been screened for above 0.1% in each article.
3. Postponing notification on the grounds of a tonnage below 1 t/year. The tonnage threshold only concerns Article 7.2.
4. Declaring the concentration in the purchased raw material instead of in the finished article: the value is wrong as soon as an additive is introduced via a masterbatch.
5. Identifying the article by an internal code alone. A waste operator must be able to recognise the article from the database.
6. Treating the submission as a one-off event. A 2021 dossier that has not been reviewed is behind by several Candidate List revisions.

7. Updating your SCIP dossier: three triggers, one rule

The rule: after 5 January 2021, when a substance contained in an article is added to the Candidate List, the SCIP notification must be submitted or updated at the next supply or placing on the market of that article, or after an import.

Two practices make the whole process more reliable: keeping a version log (date, list version, content changed, submitter) and aligning the SCIP calendar with that of supplier SVHC declarations, so that a single campaign feeds both.

8. 10-point SCIP checklist

1. Inventory of articles placed on the market, with mass, CN/TARIC code and import status.
2. Documented breakdown into articles, including for complex objects and packaging.
3. Dated Candidate List version for the latest campaign (253 entries as of 4 February 2026).
4. Supplier declarations per article: CAS, EC, concentration in the article, list version, signatory.
5. 0.1% w/w calculation sheets per article, with substance mass and threshold.
6. SCIP dossiers submitted for each article exceeding the threshold, with SCIP number archived.
7. Article node tree consistent with the bill of materials and the chosen breakdown.
8. Article category (CN/TARIC code) and material category completed.
9. Safe use and dismantling instructions available, or identification-only option explicitly justified.
10. Update log and review calendar at each half-yearly revision of the list.

9. Going further

This page explores a specific point of the pillar guide on supplier REACH compliance, which covers the allocation of responsibilities in the supply chain and the table of evidence.

• Service page: from document collection to evidence: centralisation of supplier and product data, document collection and deadline tracking.

Tracklab's role

Breaking down into articles, choosing nodes, drafting safe use instructions and regulatory decisions remain the responsibility of Regulatory, Quality and Purchasing teams. What becomes unsustainable over time is the documentation mechanics: hundreds of references, masses, concentrations, list versions and deadlines that shift twice a year.

Tracklab is a centralised supplier and product data management platform for manufacturing and food industries. It centralises supplier and product data, automates document collection, uses AI to extract critical data from documents and tracks renewal deadlines, so that the SCIP dossier is based on evidence linked to the right articles, rather than on an annual campaign rebuilt from scratch. It makes it possible to link evidence to the relevant articles, at the right level of breakdown.

Official sources

• Directive 2008/98/EC on waste, consolidated text – EUR-Lex
• Regulation (EC) No 1907/2006 (REACH), consolidated text – EUR-Lex
• SCIP database – ECHA
• SCIP: information for suppliers of articles – ECHA
• Recommendations for a successful SCIP notification – ECHA (PDF)
• Candidate List of substances of very high concern – ECHA
• Notification of SVHCs in articles in the SCIP database – Ineris (PDF)
• SVHCs and articles – French national REACH regulatory helpdesk, Ineris
• Article L. 541-9-1 of the French Environmental Code – Légifrance
• FAQ on Article 13-I of the AGEC law – French Ministry for the Ecological Transition (PDF)