SCIP notification: who must file and how (2026)

Who actually has to file

The duty comes from Article 9(1)(i) of Directive 2008/98/EC, inserted by Directive (EU) 2018/851, which obliges any supplier of an article — as defined in point (33) of Article 3 of REACH — to give ECHA the same information it already owes its business customers under REACH Article 33(1), as from 5 January 2021. REACH's definition of supplier is deliberately wide: the producer or importer of an article, a distributor, or any other actor in the supply chain who places an article on the market. So the SCIP duty is not a manufacturer duty. An EU importer bringing in finished goods, an assembler putting third-party components into a complex object, a wholesaler reselling to shops, a fulfilment company that takes title — all of them are suppliers of articles.

The trigger is a Candidate List substance present above 0.1% weight by weight. The Candidate List stood at 253 entries after the update of 4 February 2026 (checked 2026-08), and several entries are groups, so the number of individual substances captured is higher. ECHA updates the list roughly twice a year, and inclusion has immediate legal effect — there is no transition period — so the list revision you screened against is part of your evidence and should be dated.

The 0.1% is measured per article, not per finished product. In case C-106/14 the Court of Justice held that the threshold applies to each article incorporated as a component of a complex object, the principle usually shortened to "once an article, always an article". A cable containing a plasticiser above 0.1% inside an appliance that is 0.001% by total mass is still notifiable. This is why sellers of assembled goods routinely discover one reportable part — a grip, a seal, a connector, a solder joint, a coated fastener — in a product they had assumed was clean.

One practical limit that non-EU sellers hit immediately: SCIP is an EU-established-supplier duty. A US, UK or Chinese manufacturer has no SCIP obligation and, in practice, no route to discharge one — the submission model is built around EU or EEA legal entities with an ECHA account. If you sell into the EU from outside it, the notification falls on whoever imports: your EU entity, your importer of record, or your customer. Northern Ireland is outside the duty as well, because the Waste Framework Directive is not among the EU acts applied to Northern Ireland under the Protocol / Windsor Framework annex.

The retailer exemption, and how sellers lose it

ECHA's position is that retailers and other supply-chain actors supplying articles directly and exclusively to consumers are not covered by the SCIP notification duty. The logic follows REACH: the Article 33(1) communication obligation runs towards recipients of articles — industrial or professional users and distributors — and consumers are expressly excluded from that definition. Once the article reaches the consumer, the waste-stage information is already in the database from upstream, so a further notification adds nothing.

The exemption is narrower than sellers assume, because both words are load-bearing. "Directly" means you supply the consumer yourself; if you also supply a wholesaler, a shop, an installer, a hotel, an office or any other business, that channel is a B2B supply and the exemption does not cover it. "Exclusively" means all of your supply, not most of it — a shop with a consumer storefront and one recurring corporate account is not an exclusive consumer supplier. And the exemption is about the retail act only: it does not travel upstream. If you import the goods yourself and then sell them to consumers, you are the importer as well as the retailer, and the importer duty stands. That combination — non-EU brand, own EU import entity, direct-to-consumer store — is the most common way an online seller wrongly believes it is exempt.

Two further clarifications worth having in writing. Selling on a marketplace does not change the analysis: the question is who places the article on the EU market and who your buyers are, not the platform. And the exemption removes only the SCIP notification; your REACH Article 33(2) duty to tell a consumer, on request and free of charge within 45 days, whether an article contains a Candidate List substance above 0.1% survives untouched.

What a SCIP dossier actually contains

A notification identifies the article, the substance, and how to handle both safely at end of life. On the article side you provide a name and at least one primary article identifier with its type — a GTIN or EAN, a part number, a catalogue number, a model reference — plus an article category based on the EU Combined Nomenclature / TARIC customs classification, the relevant material category, and whether the article was produced in the EU. On the substance side you select the Candidate List entry from ECHA's picklist and give a concentration range rather than an exact percentage, choosing from predefined bands starting at 0.1% to below 0.3%, together with where in the article the substance sits.

The third block is the one that is genuinely written rather than looked up: safe use instructions. ECHA's requirement is information sufficient to allow safe use of the article across its whole life cycle — service life, disassembly and the waste or recycling stage — so that each actor can take the risk-management measures that follow from the substance being there. A generic "handle with care" is the classic reason a notification is technically accepted but practically useless; a usable entry says what to avoid, how the part comes apart and what a waste operator should know.

For complex objects, the structure mirrors the product: you notify the complex object and the articles inside it that carry the substance, ideally by referencing the SCIP numbers your suppliers give you rather than re-describing their parts. Notifying costs nothing — ECHA charges no fee for SCIP, the ECHA account and Cloud Services are free, and the SCIP format itself is published free of charge. The cost is entirely in supply-chain data collection and in the internal work of keeping notifications current.

The two submission routes

Route one is manual, through the ECHA Submission Portal. You need an ECHA account for your legal entity, acceptance of the SCIP terms, and a user holding the "Submission portal manager" role. From there you either prepare the notification in IUCLID — the harmonised format SCIP dossiers use, available as free desktop software or as IUCLID Cloud inside ECHA Cloud Services — and upload the resulting dossier file, or you build it directly in the portal's own interface. For a seller with a handful of SKUs and a stable range, this is the whole implementation: a few hours of onboarding and then an occasional new dossier.

Route two is system-to-system (S2S), ECHA's public API into the submission module. Your own system — or a compliance platform acting for you — sends the IUCLID SCIP dossier content and receives back a submission number that you use to pull the submission report. S2S also accepts simplified notifications. It is the right route above roughly a few hundred articles, or when SKUs change constantly, because the failure mode of the manual route at scale is not difficulty but drift: notifications that were correct at launch and were never updated when a formulation, a supplier or the Candidate List changed.

Whichever route you use, a successful submission returns a SCIP number: a 36-character identifier in UUID form, generated at the first successful submission of that article and kept for every later update of it. That stability is the point — the number is the handle your customers quote, so an update never invalidates what you have already shared. Two operational cautions from ECHA's own guidance: check the submission report rather than assuming acceptance, and if you export SCIP numbers from the portal to send to customers, strip duplicate rows and failed notifications before you send the file.

Simplified notifications and the referencing trick

The simplified SCIP notification (SSN) exists so the same article is not documented from scratch by every entity that touches it. An SSN does not require an IUCLID dossier at all: you refer to information already submitted to ECHA by another submitter by quoting the relevant SCIP number, adding only what is specific to your own placing on the market. The intended users are distributors, and any situation where one article reaches the EU market through several legal entities — subsidiaries of the same group, a second importer, a rebranded variant of an identical part.

This turns the SCIP number into the practical unit of supply-chain compliance. If you are a supplier, publish yours: quoting a SCIP number in your product data sheet stops customers from re-notifying your parts and stops them sending you questionnaires. If you are a distributor or assembler, demand it — a supplier that cannot give you a SCIP number for a part it has notified either has not notified it or cannot find the submission, and both are your problem the moment an inspector asks. Referencing is voluntary, not mandatory; it does not transfer your legal duty, it only removes duplicated work.

Getting the data out of your supply chain

Nearly all SCIP effort is upstream data collection, and the sequencing that works is: screen your bill of materials against the current Candidate List revision, request declarations only for the parts that plausibly carry a listed substance, and escalate to testing only where a declaration is refused or implausible. Blanket questionnaires to every supplier produce low response rates and are the main reason SCIP programmes stall.

Ask for the data in a standard format so it arrives machine-readable. IPC-1754 is the one built for this job — an XML materials-declaration standard for article products that explicitly supports the data elements needed for reporting to SCIP under the Waste Framework Directive. IPC-1752B and IEC 62474 are also usable. The widely deployed IPC-1752A is the trap: it is a fine full-materials-declaration format, but it is not designed to carry the SCIP fields, so data arriving in it has to be extracted and re-keyed. If your supplier questionnaire still says "IPC-1752A", that is a cheap thing to fix and it removes a manual step from every future notification.

Whatever you collect, keep the substance data, the Candidate List revision you screened against, and the resulting SCIP numbers in the same record as the SKU. The re-check that catches problems is not the initial screen; it is the one you run after each Candidate List update, when a part that was compliant last year silently becomes notifiable.

Penalties, enforcement and where SCIP stands in 2026

Penalties are national, and the honest picture is uneven. Germany is the clearest: § 16f of the Chemikaliengesetz carries the SCIP information duty, and since 24 November 2023 § 26(1) no. 6a makes an intentional or negligent failure to provide the information — or providing it incorrectly, incompletely or late — an administrative offence punishable by a fine of up to €10,000 per case. Most other member states enforce SCIP through their general waste or chemicals penalty provisions rather than a dedicated SCIP fine, which means the exposure is real but not separately published. Much larger figures circulate in online summaries; we could not match them to a national statute, so treat them as unverified and check the law of the member state you actually sell into.

The practical enforcement risk is usually not the fine anyway. It is a customer audit — large EU buyers now ask for SCIP numbers as a condition of supply — or a market surveillance check that starts with a restricted substance and ends up examining your article documentation. ECHA's Enforcement Forum agreed a project for inspectors to check whether products and mixtures on the market comply with restrictions on hazardous substances, explicitly including online sales; that project targets restrictions rather than SCIP itself, but it puts the same articles and the same documentation in front of the same inspectors.

One 2026 status note that confuses people: ECHA reported from 29 January 2026 that technical problems were delaying SCIP dissemination — the publication of notifications in the public database — and the delay persisted through the spring. Submissions are accepted normally throughout; only the public appearance of the record is behind. If your submission report says successful, you have complied, and no resubmission is needed. Scale, for context: the database was reported to hold more than 17 million notifications by spring 2026, up from about 15 million a year earlier, so the compliant population is large and growing.

Sources (checked 2026-08)

Legal basis: Directive 2008/98/EC (Waste Framework Directive) Article 9(1)(i), as inserted by Directive (EU) 2018/851 — duty on any supplier of an article as defined in REACH Article 3(33) to provide the REACH Article 33(1) information to ECHA as from 5 January 2021, and the ECHA-maintained database open to waste treatment operators. REACH Regulation (EC) No 1907/2006 — Article 3(33) supplier of an article, Article 3(35) recipient of an article (consumers excluded), Article 33(1) and 33(2). Court of Justice, Case C-106/14 (2015) — the 0.1% w/w threshold applies to each article incorporated in a complex object.

ECHA: the SCIP pages (SCIP, Suppliers of articles, SCIP database, SCIP format, SCIP support, Tools to prepare and submit SCIP notifications, System-to-system submission service) and the SCIP documentation set — Detailed information requirements for the SCIP database, Requirements for SCIP notifications, Preparing a SCIP dossier, SCIP database notifications, Key tips for successful SCIP notifications, Simplified SCIP notification and referencing, Validation rules for SCIP notifications, and the S2S submission manual. These give the duty-holder scope and the retailer exemption, the information requirements (article identifiers, CN/TARIC-based categories, concentration ranges, safe use instructions), the free-of-charge status, the ECHA account and Submission portal manager role, the SCIP number as a 36-character UUID assigned at first successful submission, and the SSN referencing mechanism. ECHA CHEM Candidate List — 253 entries after the update of 4 February 2026. ECHA news — the Enforcement Forum project on restrictions in products including online sales; the SCIP database notice on dissemination delays reported from 29 January 2026.

National penalties: Chemikaliengesetz § 16f (supplier information duties) and § 26(1) no. 6a with § 26(3) — fine of up to ten thousand euros; entry into force of the Fourth Act amending the Chemicals Act on 24 November 2023, as reported by IHK Karlsruhe and trade-e-bility. Supply-chain data formats: IPC-1754 (materials declaration for article products, supporting the SCIP data elements), IPC-1752B and IEC 62474, and the IPC-175x family documentation via electronics.org / IPC. Northern Ireland scope: the Waste Framework Directive is not among the acts applied under the Ireland/Northern Ireland Protocol annex, so Northern Ireland companies are not obliged to notify.

Check your specific case

• SCIP Notification Checker
• SVHC Duty Checker — REACH Article 33 and SCIP
• REACH SVHC and restriction checker

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