As the deadline for companies to submit data to the European Union’s Substances of Concern In articles, as such or in complex objects (Products) (SCIP) database^[1] approaches, executives that are yet to take action should ask themselves how they are able to ensure EU market access and maintain their direct and indirect revenue-generating processes.

“The process for submitting information into the SCIP database begins Oct. 28, 2020, and companies must have submitted relevant data by Jan. 5, 2021. Only an EU-based entity registered through the SCIP software may submit data,”^[2] which means many North America-based companies will have to rely on their distributors and EU importers or seek out a third-party service provider.

James Calder, vice president of compliance and regulatory programs at Assent Compliance Inc., questions whether companies that leave the process up to importers are aware that, by placing the data submission requirements in someone else’s hands, they have put all their EU market revenue at risk. Non-EU businesses that sell in the EU must not just learn what the technical data requirements are for submissions into the SCIP database but must also be able to assign global business responsibilities to ensure continued market access. That will most definitely include due diligence into supply chains to gain the transparency needed for accurate data submissions. Assent has put together a template that can help navigate the process.^[3]