SCIP notifications are filed part by part, not product by product

In February, at an industrial equipment maker I work with, a German buyer's request fit in one line: "please send us your SCIP numbers." The QHSE manager called me the same day. His REACH declarations were current and his Article 33 procedure was written down, but nobody in the company had ever submitted anything to the database. The buyer had already looked: the database is public, and he had found nothing. Here is what the obligation actually covers.

The SCIP database, for Substances of Concern In articles as such or in complex objects (Products), is run by the European Chemicals Agency (ECHA). Since January 5, 2021, Article 9(1)(i) of the EU Waste Framework Directive (2008/98/EC, as revised in 2018) requires notifying any article placed on the EU market that contains a substance from the REACH Candidate List above 0.1% weight by weight. The stated purpose is traceability all the way to waste operators. The immediate effect plays out between customers and suppliers.

The 0.1% threshold is assessed article by article, never on the finished product

An "article" under REACH is an object defined by its shape and function rather than its chemical composition: a screw, a gasket, a cable sleeve. An assembled product is, in the regulation's terms, a complex object made of articles.

The Court of Justice of the European Union settled the calculation on September 10, 2015 (case C-106/14): in a complex object, every incorporated article keeps its own 0.1% threshold, calculated on its own weight. ECHA turned it into a rule with an explicit name, "once an article, always an article." An article stays an article however deep it sits in the assembly.

The practical consequence: measured against the weight of an assembled valve, the lead in a brass gasket disappears below the threshold. Measured against the gasket alone, it clears it comfortably. The gasket triggers the notification, not the valve. At the equipment maker from February, the product-level analysis had concluded there was nothing to notify. The part-by-part analysis surfaced a whole series of references.

The Candidate List has held 253 substances since February 4, 2026, and grows roughly twice a year. Each update can pull articles into the obligation that were outside it the day before.

Every supplier of the article notifies, at each link in the chain

The duty covers every supplier of articles within the meaning of REACH Article 33: the producer or assembler established in the EU, the importer, the distributor. Each carries its own obligation, even when someone upstream has already notified.

Two cases sit outside the scope. Retailers supplying articles directly and exclusively to consumers do not have to notify. And suppliers established outside the EU have no direct obligation: their European importer carries it, with whatever data the supplier is willing to hand over. If you import components from Asia, the notification is yours.

Good to know: the Waste Framework Directive is transposed by each member state, so enforcement and penalties are national and vary from one country to the next.

Notification does not replace Article 33. The information still travels down the chain to your business customers, and to any consumer who asks for it within 45 days. SCIP adds a recipient, ECHA, and it puts your answer on the public record.

The dossier is built from data your suppliers already hold

A notification contains the identification of the article (name and a primary identifier, such as a European Article Number), its category from a picklist derived from the EU's TARIC customs nomenclature, the name of the Candidate List substance, its concentration range chosen from predefined bands, the category of material or mixture it sits in, and a safe use instruction, or a checked box stating that identifying the substance is enough. Submission goes through ECHA's portal and is free of charge.

None of this data originates with you. It comes from supplier declarations, and the question to ask is the same one Article 33 already requires, reference by reference: does the part contain a Candidate List substance above 0.1% of its weight, which one, at what concentration, in which material?

Two mechanisms keep you from redoing upstream work.

The simplified SCIP notification (SSN). A distributor reselling an unchanged article references the supplier's SCIP number and receives its own number in return, without building a dossier.

Referencing. An assembler incorporating a component without changing its shape or composition references, inside the dossier for its complex object, the notification already submitted for that component.

Good to know: ask for the SCIP number in your supplier questionnaires, alongside the Article 33 declaration, and look it up in the public database before relying on it. A number that resolves to nothing does not cover you.

Start by crossing your bill of materials with the Candidate List in its February 4, 2026 version, article by article. For every reference above the threshold, collect the supplier's SCIP number or the notification data, then notify or reference before the article goes on the market. And set a reminder on every list update: the list decides what you will have to notify next.

FAQ

Do we notify every unit we sell, or every article?

Every article, once. A SCIP notification covers an article or complex object as placed on the market, identified by its reference, not each individual unit or shipment. It must be updated if the article's composition changes or if a list update brings a new substance into scope.

Does a distributor have to notify an article its supplier already notified?

Yes, the obligation applies to each supplier in the chain. The distributor can use the simplified SCIP notification, which references the supplier's SCIP number instead of a full dossier, and receives its own SCIP number in return.

Do suppliers based outside the EU have to notify to SCIP?

No. The obligation falls on actors placing articles on the EU market, so a non-EU supplier has no direct duty. The EU importer carries the notification, using the substance data the supplier provides.

Does a SCIP notification replace communication under REACH Article 33?

No, the two coexist. Article 33 requires informing business customers when the article is supplied and consumers within 45 days of a request. SCIP notification sends the same information to ECHA's public database before the article is placed on the market.