Short answer
EU suppliers of articles containing Candidate List SVHCs above 0.1% weight by weight at article level are currently subject to SCIP, with role-specific exceptions. In December 2025 the Commission proposed discontinuing the database and reporting duty, but a proposal does not repeal current law.
Key takeaways
- Continue complying until an adopted amendment actually applies.
- The 0.1% threshold is assessed for each component article retaining its identity.
- SCIP requires article identity, substance location, concentration range, and safe-use information.
- REACH Article 33 and internal substance traceability do not automatically disappear if SCIP changes.
This content is a practical overview, not legal advice. Always verify the current legislation and the requirements that apply to your product. Research uses official primary sources; competitor content is used only to identify questions and content gaps.
Who is in scope?
EU producers and assemblers, EU importers, distributors, and other suppliers placing relevant articles on the market may be covered. Retailers supplying articles directly and exclusively to consumers are excluded from the notification duty described by ECHA. Assess the role for each trade flow and legal entity.
The threshold applies to the article in the complex object
A complex product may contain many articles. If a screw, cable, or seal retains its particular shape, surface, or design, the 0.1% threshold is assessed for that article rather than diluted against the total product weight. The BOM must preserve the relationship between complex object and component articles.
What data is required?
The notification includes article identity, category, Candidate List substance, concentration range, material or mixture category, location, and safe-use information. The duty holder remains responsible for data quality even where data comes from a supplier or an existing SCIP submission.
From supplier response to validated dossier
Match the supplier article to internal identity, verify Candidate List date and concentration, build the complex-object hierarchy, validate mandatory fields, and record why referencing or simplification is justified. A technically successful submission does not prove that source data is correct.
Manage the repeal proposal without losing control
Track the legislative file while maintaining reporting until an amendment is adopted and applicable. Separate SCIP-specific fields from underlying REACH and product data. This allows future reporting reduction without losing knowledge about SVHCs in products.
Data governance and change
Candidate List updates should trigger portfolio review and, where needed, new supplier requests. Version article identities, dossier numbers, submissions, errors, and decisions. Define when a changed article identity or SVHC status requires an update and a new submission.
How Verca can support the process
Verca can organise BOMs, supplier evidence, SVHC status, and product versions. Its data may support reporting preparation, while the customer remains responsible for the legal duty and ECHA submission.
Frequently asked questions
Was SCIP abolished in 2026?
No. The Commission proposed repeal, but the existing duty remains until the legislative process produces an applicable amendment.
Does 0.1% apply to the whole product?
No. In a complex object, the threshold is assessed for each component article that retains its identity.
Can a distributor have to notify?
Yes. ECHA includes EU distributors and other suppliers, excluding retailers supplying directly and exclusively to consumers.
Would REACH Article 33 disappear with SCIP?
Not through the SCIP proposal itself. REACH communication duties are legally separate.
Official sources
Primary sources used for this guide.