Methodology
How the SCIP Notification Checker reads WFD Art. 9(1)(i)
This tool walks you through a five-question decision tree that mirrors Article 9(1)(i) of the EU Waste Framework Directive (Directive 2008/98/EC as amended by Directive (EU) 2018/851) and the ECHA SCIP database submission guidance. It is a decision-support tool — not legal advice and not a certificate of compliance.
The 0.1% w/w threshold is interpreted strictly: WFD Art. 9(1)(i) reads “above 0,1 % weight by weight”, so a concentration of exactly 0.1% does NOT trigger the SCIP notification duty.
The retailer exemption applies only when the supplier places articles “directly and exclusively” on the market for consumers. A retailer with any B2B leg falls back into scope.
Packaging-only items are assessed under the Packaging and Packaging Waste Directive, not under WFD Art. 9(1)(i); the tool flags them as out of SCIP scope.
Dataset provenance
- ECHA Candidate List version: 2026-02-04 (253 substances)
- Source: ECHA Candidate List of Substances of Very High Concern for authorisation
- Retrieved: 2026-06-16
- Last verified: 2026-06-16
- Submission deadline status: continuous since 2021-01-05
Regulatory status — a repeal has been proposed (not yet adopted)
On 2025-12-10 the European Commission presented the Environmental Omnibus — proposed repeal of the SCIP database — part of an Environmental Omnibus simplification package amending Article 9 of the Waste Framework Directive. On 10 December 2025 the European Commission presented an Environmental Omnibus simplification package that includes a legislative proposal to repeal the SCIP database and its reporting obligation, pointing to the Digital Product Passport as a future alternative. This is ONLY a proposal: it must still pass the European Parliament and the Council under the ordinary legislative procedure and has NOT been adopted. Until it is adopted and enters into force, the SCIP notification duty remains fully in force and companies must continue to notify. This tool's verdict reflects the law currently in force and does NOT assume the proposed repeal.
What this means for you now: the SCIP notification duty is still fully in force, and this tool's verdict reflects the law currently in force — it does not assume the proposed repeal. Watch the EU institutions' progress on the file before relying on any future change.
Sources
- Waste Framework Directive Article 9(1)(i) — Directive 2008/98/EC as amended by Directive (EU) 2018/851, Article 9(1)(i)
- ECHA SCIP database — Substances of Concern In articles, as such or in complex objects (Products)
- REACH Article 33 — duty to communicate — Regulation (EC) No 1907/2006, Article 33
- IUCLID 6 SCIP dossier format — ECHA dossier preparation guidance for SCIP notifications
What this tool does not do
- It does not submit a SCIP dossier on your behalf — submission happens through ECHA IUCLID.
- It does not certify regulatory compliance and is not legal advice.
- It does not assess REACH Art. 7(2) substance registration duties.
- It does not replace a competent-authority opinion in cases of legal ambiguity.