Industry statements on SCIP database: mayor concerns on denomination of substances and the submission process
The database of Substances of Concern or ‘SCIP’ is raisin two mayor concerns around the automotive industry: Both on the denomination of the substances and on the submission process.
On 4 December, 2020 – the SCIP- SVHC pick list contains 281 individual substance names of which 20 have no CAS numbers (8 with EC number), 28 have no EC number (17 with CAS numbers) and 11 have neither CAS nor EC numbers. In addition, the pick list includes 21 so called group entries which do not describe individual substances at all.
In this context, ACEA and CLEPA provided a list of 402 individual substances with CAS numbers which was developed together with our partners in the chemical industry. ECHA reviewed that list and provided feedback in September 2020.
The SCIP pick list however has not been updated accordingly, resulting in the situation that substances that have been confirmed to be in scope of the candidate list cannot be reported in SCIP and automatic file transfer cannot be performed.
Additionally, ACEA, CLEPA and ACEM – the EU Vehicle Manufacturers and Suppliers Associations – made their interpretation of the term Legal Entity (LE) in SCIP.
Today it is considered as being crucial to all our members to clarify the term LE in the scope of the WFD and SCIP, as this is the first step for each company to access IUCLID and to manage its company structure. There are related uncertainties that prevent our member companies from starting to work on the SCIP Notifications, as such.
In: CLEPA News, Environment & Energy, Materials & Substances