SCIP: Deadline vs. "In Force" Date

Question: January 5, 2021, has been referred to as the “deadline” for the Substances of Concern In articles, as such or in complex objects (Products) (SCIP) database, the date by which companies must collect specific article-level information to submit to the database. However, the European Chemicals Agency (ECHA)’s website states that requirements apply “as from 5 January, 2021,” which sounds more like a starting point than a deadline. Is this the case?

Answer: Technically, January 5, 2021, is not a deadline, but rather the date at which the SCIP database enters into force. This means that economic operators (companies, suppliers, manufacturers, etc.) placing any article containing Substances of Very High Concern (SVHCs) over the 0.1 percent weight-by-weight concentration threshold on the European Union (EU) market are obliged to submit required data to the SCIP database. In this sense, it is a deadline for many actors. However, if the article or complex product containing the article was placed on the EU market before that date, this is not required.

Article is current as of 2020-05-01.

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