The candidate list of the SVHC list or Substances of Very High Concern is updated twice a year. One can normally expect the list of candidates to rise after every update. But if the substances are broken down individually, the list of the actual number of reportable substances will rise to quite a larger count.
How are the SCIP database notifications affected by this?
If the restricted materials are used in the electrical or electronic goods in the EU market in a concentration above 0.1% weight by weight, it must be notified to the SCIP database. This means every time the candidate list is modified, every new SVHC that is added to the SCIP database becomes relevant to you.
As a business yourself, you need to keep a constant check if the products you are manufacturing contains any newly added SVHC. But it is always better to start from the basics and know what the entire set of SVHCs is.
How to manage SCIP notifications?
If you are the manufacturer of any discrete industry, here are the steps that you will need to follow in case the SVHC candidate list is updated:
- Make sure that you update your product compliance solution and include the new SVHCs in them. You need to have the product compliance solution ready with you in case of tracking and maintain the details of the new SVHCs.
- You need to assess the impact of the new product on your existing portfolio. Check the articles or complex objects in which it is present.
- Do not waste any further time and contact your supplier right away. You need to start initiating the data collection right from your supply chain. Next, you need to aggregate the entire information and close the knowledge gap. This is not at all needed for the articles where you have already provided a full material declaration.
- The next step involves the assessment of the concentration of the new SVHCs in the articles and the complex objects which you have been manufacturing. If the concentration in any case is above 0.1% w/w, you will have to update the notification to the SCIP database.
- The last step would involve updating the Article 33 declarations and the SCIP notifications.
To avoid any further miscommunication, it is the best to keep a close check on the REACH SVHC List periodically.