On the SCIP dissemination page (https://echa.europa.eu/scip-database) the supply chain is not revealed directly, as no company names are exposed, not even of the reporting company.
To respect other companies’ requirements for supply chain confidentiality, it is strongly recommended not to include any company names (neither your own nor your customer’s) in the names and descriptions of Modules/MDSs as those names might become visible in the SCIP dissemination portal.
How to handle received legacy MDSs without SCIP information?
Modules/MDSs released prior to IMDS Release 13.0 do not contain SCIP information like Article Categories, Material Categories, Production in EU, etc.
These MDSs are still valid and can be proposed or published.
Just like the regulatory information collected in the regulation wizard, SCIP information (or the lack thereof) is not to be considered acceptance criteria for MDSs. SCIP INFORMATION IN IMDS IS NOT MANDATORY AND MUST NOT BE USED AS A REASON FOR REJECTION.
(Also see the question “How is legacy data handled in SCIP submissions?” below.)
How are SCIP submissions processed in IMDS?
Only own released component Modules/MDSs can be submitted to SCIP. Submissions are not available for editable components or received MDSs.
When initiating a submission of a component, it is not immediately submitted, but put in a queue. You can view the status of your submissions in the Functions / SCIP Submissions screen.
The status of not yet submitted components is “new”. Once the submission is initiated, the status first changes to “running” and then to “submitted”, at which point the component also receives a SCIP Submission No.
Once the component is submitted, it is being processed in the SCIP database. IMDS regularly checks on updates of previously submitted components to update the status, but the speed with which they are being processed depends on the current workload of the SCIP database.
Once the submission has been processed in the SCIP database, its status will be set to either “completed” and receive a SCIP No. or to “failed” in case the submission did not pass the validation checks implemented by ECHA.
Which data is submitted to SCIP?
During the submission process, a SCIP dossier is automatically created by IMDS and submitted to SCIP on your behalf.
The dossiers created by IMDS do not represent the full composition of the Module/MDS. Instead, the dossiers only contain information about the submitted component itself, each contained article (lowest level component with >0.1% of at least one SVHC) as well as the first level components directly underneath the top node. Any other components are not mentioned in the dossier.
While the created dossiers fully comply to the requirements by ECHA, they do not contain every information about the Module’s/MDS’s details. The following is included in every dossier:
Article Name
Primary Article Identifier (see below)
Article Category
Production in EU
Required safe use instructions
Material Category
Mixture Category
Additional Material Characteristics
Not included is information about quantities and weights, as well as data not available in IMDS (e.g., other names or identifiers, pictures, etc.). While the SCIP dossier format requires the portion for each SVHC within the article, this information is not disclosed in detail, but reported by using the “0% - 100%” range offered by ECHA for selection.
The component’s Part-/Item No. is used as its Primary Article Identifier in the dossier. In case a Part-/Item No. is not available, the following applies:
If the submitted component itself lacks a Part-/Item No., but has been sent or proposed, the Part-/Item No. provided for the first recipient is used.
For referenced own components or component nodes without a part-/item no, their parent component’s part-/item no. (if existing) is used in combination with their description.
In case the parent component does not have a part-/item no. as well, the part-/item no. of the submitted component (top node) is used in combination with the description of the own components.
In every other case where the part-/item no. is not available, the component’s description is used.
For more details about the submitted content, please also refer to the next section (“Which substances are considered in a SCIP submission?”).
Which substances are considered in a SCIP submission?
At the point of this writing (November 2021) not all substances on the SVHC candidate list are recognized by SCIP. This means that not all substances with the “SVHC” flag in IMDS can be reported to SCIP.
To easily identify the substances which need to be reported, the “SCIP SVHC” substance group has been created. This group is available as a filter in the Module/MDS Ingredients screen as well as a search criterion in the substance search or the Where-Used Analysis.
Depending on the material’s classification and the assigned application code, certain substances are also not included in the dossier, because they do not retain their properties which make them an SVHC in these cases. The following table shows which substances are ignored in which cases:
Substance
CAS Number
Is an SVHC in Classification 7.2
Is an SVHC in Classification 8.x
Diboron trioxide
1303-86-2
No
No
Lead-monoxide
1317-36-8
No
No
Lead titanium zirco-nium oxide
12626-81-2
No
No
Lead(II,IV)-oxide
1314-41-6
No
No
Lead-titanium-trioxide
12060-00-3
No
No
Lead
7439-92-1
No
Yes (No, for Application Codes 10a-d)
Additionally, all SVHC within materials of classification 9.x can be ignored when initiating a submission. If the Module/MDS contains at least one SVHC in such a material, the user will be asked whether they want to include classifications 9.x in the submission or not.
Can I analyze for MDSs which need to be submitted to SCIP?
While the Where-Used Analysis allows users to analyze for all their components containing substances in the “SCIP SVHC” substance group, the Where-Used Analysis does not consider the substance’s portion within the article, the classification or assigned application code.
Please also note that the Where-used Analysis offers the possibility to search for substances >0.1%, but this refers to the substance’s portion within the homogeneous material, not within the article.
For your convenience, IMDS will not allow unnecessary submissions: for components which do not contain a large enough portion of SVHC in at least one of the included articles the submission is not possible.
What do I need to be able to submit to SCIP?
To submit data to SCIP from within other systems like IMDS, an “S2S Key” is required. This is a file downloadable in the ECHA Submission Portal, which is used to identify a Legal Entity at SCIP instead of using a user ID and password.
Once an S2S Key has been downloaded, an IMDS Company Administrator can upload it to IMDS by assigning it to their company or Org.-Unit in the Administration / Company screen.
When uploading an S2S Key, IMDS performs a check to verify that the S2S Key matches the basic format. The file needs to have two lines with the second containing the LE’s UUID, name and the actual S2S Key. S2S Keys created after September 2021 also contain the creating user’s name. IMDS does not check the validity of the key or whether it belongs to the company it is uploaded for. Please pay attention to upload the correct S2S Keys to avoid unintentional submissions into wrong Legal Entities.
When submitting an MDS assigned to an Org.-Unit for which multiple S2S Keys have been uploaded, the user will be asked to select one of them to be used for this submission. This will determine which Legal Entity the information will be submitted to in SCIP.
How is legacy data handled in SCIP submissions?
The created SCIP dossier contains information about e.g. article and material categories. This information is not available in Modules/MDSs released prior to IMDS Release 13.0.
To still allow the submission of such Modules/MDSs, users can opt to “assume SCIP defaults” when initiating a submission. By selecting this option, the following default values will be reported to SCIP for legacy components and materials released, for which no SCIP information exists:
“Production in European Union” will be set to “no data”.
“SVHC Safe Use Instructions Required” will be set to “no”.
“Article Category” will be set to Taric Code “8708999790”.
“SCIP Material Category” and “Additional Material Characteristics” will be set based on the material’s classification (see next question below).
These default values will only be used in the submission to SCIP and will not be updated in existing Modules/MDSs.
How exactly are “SCIP Material Category” and “Additional Material Characteristics” based on the Material’s classification?
When creating a new Material or when changing a Material’s classification, the SCIP Material Category and Additional Material Characteristics are set automatically based on the selected Classification.
When using the “assume SCIP defaults” option during submission, both fields are filled in the dossier based on the classification of the Material referencing the SVHC.
In both cases, the following mapping table is used to determine the SCIP Material Category and Additional Material Characteristics:
No. As described above, IMDS will always include all article information in a dossier and not reference them by their SCIP No.
This means that whenever a supplier updates their SCIP submission of an MDS referenced by your company, the changes are not automatically reflected in your submitted SCIP data. You would need to resubmit.
Can I see/download the content of a submitted SCIP dossier?
