SCIP compliance: why data, not legislation, remains the real bottleneck

Juhana Jaatinen, CEO of RoHS Management Oy, told Evertiq in an interview that the biggest obstacle isn't awareness or interpretation of the regulation. It's the data itself.

“In practice, the biggest challenge is not understanding that SCIP exists,” Jaatinen says in an interview with Evertiq. “The biggest challenge is getting the data in a usable format.”

When information exists — but not in the right form

Modern electronics products are built from hundreds or even thousands of components sourced globally. While suppliers often provide material declarations, these are frequently incomplete, inconsistent, or based on different standards. Turning this fragmented input into the highly structured information required by the SCIP database is where companies lose time and resources.

“The SVHC list is updated twice a year,” Jaatinen points out. “Every time new substances are added, companies must check again whether their products are affected. This means compliance is not something you do once and forget.”

For many organisations, this reality shifts the focus away from legal texts toward internal processes. As Jaatinen puts it, the real question becomes: “How do we build a manageable system so that this does not become a permanent administrative burden?”

The companies most often caught off guard

Despite years of guidance from authorities, SCIP obligations still come as a surprise — particularly for smaller players. Jaatinen observes that small and medium-sized manufacturers and importers often assume the rules only apply to large corporations or chemical producers.

“In reality, the obligation applies to any company placing articles on the EU market if those articles contain SVHCs above the 0.1% threshold,” he explains.

This includes both EU-based manufacturers and importers bringing finished products from outside the EU. A common misconception is that compliance sits elsewhere in the supply chain — with the component supplier or the brand owner. In practice, that assumption can be costly.

“The obligation applies at each relevant level of the supply chain,” Jaatinen stresses. “It cannot be transferred.”

Equally misleading is the idea that SCIP only matters once customers start asking for notification numbers. “The legal duty is triggered by placing the product on the EU market, not by customer demand,” he adds.

Responsibility stays with the company that places the product on the EU market.

In complex electronics supply chains, the process of obtaining SVHC information most often breaks down long before submission to ECHA. The weakest point is typically data collection from multiple suppliers — especially when dealing with custom components, contract manufacturing, or production chemicals that remain in the final product.

“The legal responsibility for submitting SCIP information always lies with the company that places the product on the EU market,” Jaatinen says. “That means the manufacturer within the EU, or the importer if the product comes from outside the EU.”

Even when suppliers provide declarations, companies must still analyse, consolidate, and interpret the data. For complex products, this can mean reviewing thousands of documents, and this process takes time.

Too late is too expensive

From Jaatinen’s perspective, many of the costs and disruptions associated with SCIP stem from timing. Companies often discover SVHC issues at the very end of product development, just before market launch.

“If a product contains SVHC substances above the threshold, the SCIP notification must be submitted before the product is placed on the EU market,” he notes. “If this is discovered at the last minute, it can delay product launch, create additional administrative work, and increase costs.”

The solution, he argues, is to integrate SCIP checks into the product development phase, alongside other conformity assessments. Addressed early, compliance becomes predictable and manageable rather than disruptive.

“When handled early in the lifecycle, SCIP becomes a manageable compliance step rather than a last-minute disruption,” Jaatinen says.

The mistake that keeps repeating

With more than three decades in the electronics industry, Jaatinen still sees the same error repeated across companies of all sizes: postponement.

“The most common mistake is simply neglecting the obligation because it is perceived as too laborious and complicated,” he says. Faced with complex data requirements and unfamiliar submission tools, companies delay action — sometimes indefinitely.

“In most cases, the real issue is not that compliance is impossible,” Jaatinen concludes. “It is that companies have not defined clear internal responsibilities and practical procedures.”

Once those foundations are in place, SCIP reporting stops being an overwhelming task and becomes part of normal regulatory housekeeping. The risk lies not in the regulation itself — but in continuing to underestimate the need for a systematic approach.

More on SCIP database requirements for electronics manufacturers will be covered by Jaatinen during Evertiq Expo Tampere, taking place on 26 March. Registration is still open, and participants are encouraged to secure their tickets in advance.