To paraphrase a popular television series, “[SCIP] is coming.” Back in August, Q Point Technology announced that companies should be aware of and prepare for the Substances of Concern In articles as such or in complex objects (Products) database, also known as SCIP database. If you are new to SCIP, or compliance in general, you may acquaint yourself here. However, to provide a very brief summary, SCIP is where companies will disclose any REACH SVHC content, above threshold (i.e., 0.1% weight by weight at the individual article level, inclusive of articles used in complex objects).
ECHA is set to release the production version of the SCIP database by the end of this month. At this time, SCIP dossier submission may occur. Per the requirements of SCIP, dossier submission is expected to begin prior to the January 5, 2021 deadline. In other words, companies should be working to get REACH SVHC data into the SCIP database before January 5th.
So what can you do today to prepare for SCIP? If you do not have recent details on REACH and SVHC use information for your products, this is the obvious starting place. Assuming you do have REACH data, as current GDX consumers and Q Point clients have, what are the steps you can take prior to SCIP launch that will help you to submit a SCIP dossier?
QPoint supports system-to-system integration between Green Data Exchange (GDX) and SCIP. However, there are requirements to set up this integration on the SCIP/ECHA side. Please review the document found here for joining “ECHA’s System-to-System Integration.”
If you are already registered as a legal entity with ECHA, you may proceed to requesting access to the S2S service. If you are not registered as a legal entity with ECHA, see how to register and get your company’s ECHA accounts here.
Request access to the S2S service from REACH IT and ECHA. In order to do this, your company must be registered as a “legal entity.” Your company’s legal entity manager would submit a request for access here. ECHA would then review the request and provide a response, including approval and access. Once this has been established, your legal entity manager would provide access and roles to approved users. One vital role is that of the S2S Keys Manager. The S2S Keys Manager handles the keys for authenticated S2S calls. It is necessary that at least one user be the S2S Keys Manager so that the S2S key may be created.
To create the S2S key, the S2S Keys Manager role will need to log in and access the S2S Keys management page. After accepting terms & conditions, a key may be generated, exported, and saved. The key should be kept secure as it is necessary for client system configuration in the S2S set up. GDX will host your S2S keys securely in order to use them while submitting SCIP notifications on your behalf.
Once the keys are made available, GDX can test the connectivity to ECHA and make test submissions to a test instance of ECHA’s SCIP portal. These test submissions are temporary and will not be considered final by ECHA. Once test submissions are successful, your GDX account will be ready to submit SCIP notifications.
GDX will stay in synch with the SCIP definition and format changes on a schedule that will allow our customers to submit SCIP notifications in a timely manner to meet all obligations.
As always, please continue to follow the Q Point blog for the latest in developments for SCIP, REACH, and other material content regulations.