Simplifying Submissions to the ECHA SCIP Database

Siemens Healthineers uses BOMcheck to automatically submit our product dossiers to the ECHA SCIP database for all our 28 legal entities across Europe, under the management of our parent company Siemens Healthineers AG. BOMcheck enables Siemens Healthineers to reuse submissions made by our suppliers for their component parts in BOMcheck. We recommend BOMcheck as a practical and cost-effective solution for our suppliers to meet legal obligations.

Johann Russinger
Senior Director
Global EHS
Siemens Healthineers AG

SCIP is the database for information on Substances of Concern In articles as such or in complex objects (Products) established under the 2018 revision to the Waste Framework Directive. From 5 January 2021, all companies in Europe are obligated to submit information into the SCIP database for any products they supply which include articles that contain REACH Candidate List substances above 0.1%, with possible subsequent enforcement by Member State regulatory authorities. The reporting requirement applies to all companies in the supply chain including the original article supplier, suppliers of sub-assemblies and assemblies that contain affected articles, suppliers of finished products that contain affected articles, and resellers and distributors who supply the finished product to retailers.

BOMcheck Version 6.0 launched on 27 May 2020 captures the additional supplier information which is needed for SCIP database reporting and includes system-to-system integration to the SCIP database submission portal. Companies can use BOMcheck to manage data collection from their suppliers, roll-up the supplier parts data to create product assemblies, and generate and submit thousands of SCIP dossiers for their product assemblies automatically to the ECHA submission portal, in one go with a click of a button. All SCIP dossiers created by BOMcheck validate successfully in the SCIP database submission portal. You can also use BOMcheck to update and resubmit your product assemblies automatically when your suppliers update their parts data, for example when new substances are added to the REACH Candidate List.

Parent company can submit on behalf of all companies in the group

BOMcheck enables one company to submit data on behalf of another company on a voluntary or contractual basis, under the legal responsibility of the company concerned. This solution is useful for companies within a corporate group where the parent company wishes to submit data on behalf of its daughter companies, and for voluntary arrangements between companies (e.g. a brand owner submitting on behalf of a full and closely controlled supply chain). BOMcheck can arrange for the parent company to share their products dossiers directly with all companies within a corporate group, and for all companies in the group to automatically submit the same products dossiers to the SCIP database. BOMcheck can automatically update any submissions on behalf of all companies in the group when suppliers update information for any supplier parts in any products.

Reusing submissions from suppliers

BOMcheck enables companies to reuse submissions made by their suppliers. As highlighted below, the SCIP database allocates a SCIP number to each supplier part at the time of the first submission. The SCIP number is a random sequence of 36 hexadecimal characters, for example 1e991422-239c-4b49-8a42-3f4730aa51a0. There is no relationship between the SCIP number for one supplier part compared to another part submitted by the same supplier.

BOMcheck captures the SCIP numbers for supplier parts and includes them in companies' submissions for their products. BOMcheck also reports SCIP numbers in IPC-1752B XML files so that companies can reuse suppliers' parts SCIP numbers in assemblies that companies create for their products in in-house IT systems.

Without this solution, companies would need to create duplicate article submissions for supplier parts in their products that contain REACH Candidate List substances, including reporting

  • correct Article Category and the Material Category for each supplier part
  • correct safe use information for each supplier part

Companies that prefer not to take on obligations to report information on behalf of their suppliers will appreciate the opportunity to reuse their suppliers' submissions instead. Reusing submissions from suppliers will also be welcomed by distributors. BOMcheck can map the distributors' parts numbers to the suppliers' part numbers and use the SCIP submission numbers to make a simplified notification to the ECHA SCIP database on behalf of the distributor. When the supplier updates their information, the distributors submissions are automatically updated.

Costs

Our costs include registering the parent company, and all companies in the group, as Legal Entities with ECHA. With your permission, we will use your registered business addresses and authorised individuals in each country to register each Legal Entity with ECHA and to store the Legal Entity S2S keys in BOMcheck. We will test that the BOMcheck system-to-system integration is set up correctly for the parent company, and all companies in the group, and inform you when the integrations are in production mode and are ready for use.

To provide an affordable solution for all companies in your supply chain, our costs are based on the total annual business turnover for the company. We will use the Dun & Bradstreet service (www.dnb.com) to verify the total annual business turnover for the company.

Total annual business turnover Cost for first legal entity Cost per additional legal entity
Micro Less than 20 million Euro per year EUR 1,000 per year EUR 100 per year
Small 20 million to 100 million Euro per year EUR 2,000 per year EUR 200 per year
Medium 100 million to 2 billion Euro per year EUR 5,000 per year EUR 500 per year
Large More than 2 billion Euro per year EUR 10,000 per year EUR 1,000 per year

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