REACH defines an article as “an object which during production is given a special shape, surface, or design which determines its function to a greater degree than its chemical composition’’ and requires the supplier of an article containing an SVHC (Substance of Very High Concern) in concentrations exceeding 0.1% w/w to provide professional or industrial users with sufficient information to ensure the safe use of the article. The regulation also establishes the consumer‘s right to access the same information, with the most direct and efficient method being the SCIP database. This database collects information on SVHC substances contained in articles and complex articles, established to fulfill the obligations imposed by the Waste Framework Directive (Directive 2018/851).
The objectives behind SCIP Notification activities required from suppliers are threefold: reducing the generation of waste containing hazardous substances by supporting the substitution of substances of concern in articles placed on the EU market; making information available to further improve waste treatment operations; enabling authorities to monitor the use of substances of concern in articles and initiate appropriate actions throughout the product lifecycle, including disposal.
Articles are categorized as simple or complex (composed of multiple articles) and may contain substances or mixtures that are intentionally or unintentionally released based on their function. Analytical categorization of an article can be complex and often requires in-depth knowledge of the field as well as expert analyses. This is where Flashpoint consultants support the companies: we assist both Manufacturers of articles and those who assemble, import, and distribute them on the market. For each specific context and product type, we support and guide you through material analysis of your products, evaluation of use or market restrictions under Annex XVII of REACH, categorization of your articles (assessing whether a product can be considered an article under REACH, defining simple/complex/intentional release articles, etc.), updates on substances of interest (inclusion in the Candidate List), SCIP Notifications, and prior Authorization for use of substances in Annex XIV.
We also provide crucial support during supplier requests, as obtaining information and documents is often a critical activity, particularly (but not exclusively) during non-EU imports and in requested Laboratory analyses, for which we collaborate with a network of specialized partners tailored to your specific needs.