EU REACH can be a confusing regulation, even if you are just importing articles into the EU! At 3E Exchange, we've got you covered. When you indicate a particular item is an article, we will automatically apply the proper logic to ensure the article and the overall product its used in meet EU REACH.

An article is defined in the REACH regulation 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." This indicates that many components and parts that are purchased for use in your product are most likely unique articles.

An article can be thought of as a finished product. For example, a plank of wood flooring, a sink, or a table would be a finished product, and therefore, an article under REACH. These finished products can also be made up of smaller components that are also considered to be articles. An example could be screws, a metal bar, or a faucet.

Have questions about whether your parts are articles? Reach out to [email protected] and we can provide you additional information and direction.

Both a part that is an article and the product as a whole must meet the requirements for EU REACH substances on their own. This means that all thresholds and other requirements need to be met by the individual party. Once any material, part, or component is marked as a REACH article, 3E Exchange automatically checks if the article meets EU REACH requirements.

To review or manually change whether an individual material, part, or component is a REACH article, view the SCIP Dashboard page under My Products or My Materials. There is also a process for doing this in bulk.

To manually input SCIP data, you will want to navigate to the "SCIP Dashboard" in the navigation panel under "My Materials". You will then select "Need to be Submitted to SCIP".

You will see a list of products in your library that contain substances on the Candidate List of Substances of Very High Concern (SVHCs), which means they need to be submitted to the SCIP database according to ECHA guidelines.

To manually add data, you will start by clicking on the name of the product.

Then select "Edit and Submit SCIP Notification" on the REACH Candidate List & SCIP compliance page.

You will be directed to the SCIP data page. You will want to fill out all of the fields to the best of your ability. If you are missing data, 3E Exchange will not allow you to submit it to SCIP because ECHA will reject the information.

Note: At the very bottom of the below screenshot there is the "Sub-Articles" section. This will list any sub-articles in your product. Those sub-articles also need to have their SCIP data completed before submitting. You can click on the article name (in this case, where it says "201") and edit the SCIP data for the sub-article(s).

This feature allows you to assign the same summary data to many products or materials at the same time. It is important to note that the exact same data will be added for each product or material. If you would like to add different data depending on the product or material, use the bulk import by uploading a spreadsheet. If any fields in the process are left blank, the existing data in the products or materials will be left as is. Any fields that are completed will be overwritten to the new information, so ensure you wish to update all products and materials with that data.

To assign summary data in bulk, you will start at your product or material library. In that library, you can select the products you need to add SCIP data for, or you can just click on the "Assign Summary Data and Support Files for Multiple Products..." in the "Actions" menu below.

Select the products or materials you want to add the SCIP data about and then move to the "Edit Summary Data" step. There you will need to select the SCIP data page to add the SCIP information. You can also select the EU REACH SCIP Questionnaire.

You will then complete the fields listed according to any data that is the same for all the products selected in Step 1. If any fields are left blank, the existing data in the products or materials will be left as is. Any fields that are completed will be overwritten to the new information, so ensure you wish to update all products and materials with that data.

This is the best workflow to upload data for multiple products at one time. In order to import the SCIP data from a spreadsheet in bulk, you will need to complete our template spreadsheet available here.

The spreadsheet includes instructions for how to fill it out and what fields are required for SCIP submissions. Once you've completed the spreadsheet, you will navigate to your "My Products" page. Then click on the "Import Data" workflow and select "SCIP Data."

You will then select the completed file and select "Import File" to import your SCIP data.

3E Exchange can also automatically classify linked materials as REACH articles unless changed later during system use. We recommend this for most users who are not directly formulating products.

Go to Settings (account/system settings) and toggle/check "Default new Materials as REACH Articles".
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This ensures that any newly imported or linked materials/parts are automatically classified as REACH articles, saving you from having to set them one by one. (Note: Finished products are already treated as articles by default).

SCIP is the database for information on substances of concern in articles or in complex objects (products) established under the Waste Framework Directive.

Companies supplying articles containing substances of very high concern (SVHCs) on the Candidate List in a concentration above 0.1% weight by weight (w/w) on the EU market have to submit information on these articles to ECHA, as from 5 January 2021. The SCIP database ensures that the information on articles containing Candidate List substances is available throughout the whole lifecycle of products and materials, including at the waste stage. The information in the database is then made available to waste operators and consumers.

You can read more about Submitting Data to the SCIP Database.

Getting Help

If you have questions about using 3E Exchange or the material covered in this help article, reach out in chat in the bottom right-hand corner or email [email protected].