Making a Submission: EU REACH SVHC & EU Waste Framework Directive (SCIP) Request (Complex Articles)

If you are completing an EU REACH SVHC request for your customer and you declare SVHCs above threshold and complete your submission, your customer may require additional information for the EU Waste Framework Directive (SCIP) module.

You can seamlessly continue your declaration from EU REACH SVHC to the EU Waste Framework Directive in the following workflow. 

Please Note: This workflow is specifically for declaring a complex article. Find a declaration for a simple article [here]. 

Making an EU Waste Framework Directive Declaration for a Complex Article

  1. On the Supplier Portal landing page, find the EU REACH SVHC request and click Start.

  2. Before you begin, prepare the information you need to complete your declaration and then click Get Started:

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  3. On the main page, review the regulation details and the available regulation Resources.

  4. Use the checkboxes to select your product(s) and click Declare for Selected:

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  5. On the next page, review the Product Details you selected from the previous page:

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    Your submission will automatically be applied to all the selected products you sell to your client. If the products selected have different chemical characteristics or composition, then you need to go back to the previous page and only select parts with similar composition.


  6. To declare for a complex object, select "An object made of multiple assembled articles that contain other articles."

    A complex object is a product that is made of more than one article, such as a bracket with a bolt attached. 

  7. To continue with your declaration, select a Product Statement and click Next:

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  8. In the Supporting Documents section, click Upload File.

  9. Using the File Explorer, browse your organization's resources, attach the desired file, and click Open

  10. Select a file type for the uploaded file from the drop-down list.

    To remove a document, click the “x”. You can upload multiple pieces of supporting documentation.

  11. When you have uploaded your supporting documentation, click Next

  12. In the Substances section, click the Add Substance button.

    The new section opens on the right-hand side of the page. The section will remain collapsed unless the statement selected identifies the use of substances.

  13. In the Add Substance pane that opens, enter the required information marked in red:

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    For complex objects, ensure the Article Name that you’re applying is not the Product Name but is instead the name of the article where the substance is located in the complex object. For example, if a complex object such as a bracket with weld nut is the product, your articles should be the "Bracket" and the "Weld Nut" created separately, and shown with the substances declared for each article where those substances are located.  

    In above image, you can see that the complex product is the "Pulley" (under Product Name), but the substance is located in the "Winch". The "Winch" is the article.

  14. When you have finished adding your substances, click Add

  15. To add another article to your complex product, select Add Substance.

  16. Edit the Article Name to reflect the article where the substance is located: 

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    In the above example, note the new article called "Bracket". 

    You can add multiple substances to the same article by selecting Add Substance again and entering in the same article as you entered in the previous substance entry. Note how we've added two substances to the "Bracket". Always ensure you have the same spelling of the Article Name or you will create a duplicate article:

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  17. Click Add when you have finished adding substance information. 

  18. Once you have added all required articles and substances, click Next

  19. On the window that opens, click Continue to go to the EU Waste Framework declaration page.

  20. At the start of the workflow, you will be asked if the product is a single article or an object made of multiple articles.

    If more than one (1) article has previously been declared in an EU REACH SVHC submission, the corresponding EU WFD request will have "complex object" selected by default for the supplier. The “single article” selection will be disabled to prevent users from declaring complex articles as single articles.

  21. Select the Click to Edit option adjacent to the complex product name:

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    In the above example, the complex object is the "Pulley" and the article identifiers should reflect the product as it is supplied. Use the Product Name and Product Number that has been used to identify the product to your customer.

  22. Once you have saved the Complex Product Information, begin providing information for the Articles:

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  23. Under the Article and Substance Information section, select Click to Edit to open the sidebar menu.

  24. Enter all required Article information, including Article Name, Primary Article ID, Article Category Group, Production in EU Status, and Safe Use Instructions:

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  25. Next, click the declared substance to expand the sidebar:

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    Missing mandatory information is marked in red. 

  26. Under the Material or Mixture Category section, select Click to Edit:

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  27. Continue the above process for all created articles to provide all missing mandatory information and then click Next:

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  28. Click Submit to complete your submission. 
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