Cosmetic products are not directly subject to SCIP notification as formulas. However, their packaging may be concerned when it is considered an article under REACH and contains a substance of very high concern, or SVHC, above 0.1% weight by weight.
For cosmetic brands, manufacturers, importers and distributors, SCIP compliance is therefore not limited to the cosmetic formula. It may also apply to bottles, caps, pumps, applicators, cases, boxes or other packaging components placed on the European market.
What is the SCIP database?
SCIP stands for Substances of Concern In articles as such or in complex objects (Products). It is a database established by ECHA under the Waste Framework Directive.
Since 5 January 2021, suppliers of articles placed on the EU market must submit certain information to ECHA when those articles contain a substance on the SVHC Candidate List above 0.1% weight by weight.
The objective is to improve the traceability of substances of concern in products and support safer waste treatment and circular economy processes.
Why are cosmetics concerned?
A cosmetic formula, as a mixture, is not considered an article under REACH. However, cosmetic packaging can be considered an article.
This means that certain packaging components may fall within the scope of SCIP, including:
- plastic or glass bottles;
- caps;
- pumps;
- sprays;
- applicators;
- cases;
- boxes;
- accessories included with the product;
- secondary packaging.
If one of these components contains an SVHC above the regulatory threshold, information duties and, in some cases, SCIP notification obligations may apply.
Who may be concerned in the cosmetic supply chain?
SCIP obligations may apply to different actors depending on their role in the supply chain:
- packaging manufacturers;
- cosmetic brands;
- importers;
- distributors;
- companies placing products on the EU market;
- companies assembling or selling finished products with packaging.
For cosmetic brands, the main challenge is often supplier data. Even if the brand does not manufacture the packaging itself, it must be able to determine whether packaging components contain SVHCs and whether applicable obligations are properly covered.
The 0.1% threshold: a key point to understand
SCIP obligations are linked to the presence of a Candidate List substance above 0.1% weight by weight in an article.
For complex objects, this threshold must be assessed at the level of each individual article within the object. In the case of cosmetic packaging, this may require separate checks for the bottle, cap, pump, metallic spring, dip tube, box or other components.
This analysis can become complex when suppliers do not provide sufficiently detailed information on materials, components or substances used.
Why should the Candidate List be monitored over time?
SCIP compliance is not a one-time exercise. The SVHC Candidate List is regularly updated by ECHA. When a new substance is added, obligations may be triggered for companies whose articles contain that substance above the applicable threshold.
In February 2026, the Candidate List was updated with two additional substances, bringing the list to 253 entries. This highlights the importance of maintaining regulatory monitoring and reassessing packaging whenever the list evolves.
What information should be requested from suppliers?
To secure compliance for cosmetic packaging, brands should request precise information from their suppliers on the materials and components used.
Key points to verify include:
- the presence or absence of SVHCs in each component;
- the concentration of SVHCs, where applicable;
- the precise identification of the article concerned;
- up-to-date supplier declarations;
- whether a SCIP notification has already been submitted;
- any changes in materials, suppliers or manufacturing processes.
This information should be updated regularly, especially after a packaging change or an update to the Candidate List.
Checklist for cosmetic brands
To assess your SCIP obligations, it is recommended to:
- Identify all packaging elements used for the product.
- Determine which elements are considered articles.
- Request SVHC declarations from suppliers.
- Check the 0.1% weight-by-weight threshold at article level.
- Confirm whether a SCIP notification is required.
- Document the information received.
- Update the assessment after packaging changes or regulatory updates.
What are the risks of non-compliance?
Poor management of SCIP obligations can create several risks for cosmetic companies:
- lack of traceability for substances of concern;
- difficulty responding to customer or authority requests;
- delays or obstacles when placing products on the EU market;
- inconsistencies in supplier data;
- REACH non-compliance risks;
- negative impact on sustainability and product transparency strategies.
For brands operating across multiple markets, packaging data management is becoming a strategic issue. Regulatory requirements related to substances of concern, materials and packaging circularity are becoming increasingly important in Europe.
How can EcoMundo support you?
EcoMundo supports cosmetic companies in assessing their regulatory obligations related to chemical substances, packaging and access to the European market.
Our experts can help you:
- identify packaging components concerned;
- analyze supplier data;
- verify the presence of SVHCs;
- determine whether SCIP notification is required;
- structure supplier information requests;
- implement regulatory monitoring adapted to your products.
SCIP compliance should not be treated as an isolated formality. It is part of a broader approach to substance control, packaging traceability and regulatory compliance on the European market.
Would you like to check whether your cosmetic packaging is subject to SCIP obligations?
Cosmetic products are not directly subject to SCIP notification as formulas. However, their packaging may be concerned when it is considered an article under REACH and contains a substance of very high concern, or SVHC, above 0.1% weight by weight.
For cosmetic brands, manufacturers, importers and distributors, SCIP compliance is therefore not limited to the cosmetic formula. It may also apply to bottles, caps, pumps, applicators, cases, boxes or other packaging components placed on the European market.
What is the SCIP database?
SCIP stands for Substances of Concern In articles as such or in complex objects (Products). It is a database established by ECHA under the Waste Framework Directive.
Since 5 January 2021, suppliers of articles placed on the EU market must submit certain information to ECHA when those articles contain a substance on the SVHC Candidate List above 0.1% weight by weight.
The objective is to improve the traceability of substances of concern in products and support safer waste treatment and circular economy processes.
Why are cosmetics concerned?
A cosmetic formula, as a mixture, is not considered an article under REACH. However, cosmetic packaging can be considered an article.
This means that certain packaging components may fall within the scope of SCIP, including:
- plastic or glass bottles;
- caps;
- pumps;
- sprays;
- applicators;
- cases;
- boxes;
- accessories included with the product;
- secondary packaging.
If one of these components contains an SVHC above the regulatory threshold, information duties and, in some cases, SCIP notification obligations may apply.
Who may be concerned in the cosmetic supply chain?
SCIP obligations may apply to different actors depending on their role in the supply chain:
- packaging manufacturers;
- cosmetic brands;
- importers;
- distributors;
- companies placing products on the EU market;
- companies assembling or selling finished products with packaging.
For cosmetic brands, the main challenge is often supplier data. Even if the brand does not manufacture the packaging itself, it must be able to determine whether packaging components contain SVHCs and whether applicable obligations are properly covered.
The 0.1% threshold: a key point to understand
SCIP obligations are linked to the presence of a Candidate List substance above 0.1% weight by weight in an article.
For complex objects, this threshold must be assessed at the level of each individual article within the object. In the case of cosmetic packaging, this may require separate checks for the bottle, cap, pump, metallic spring, dip tube, box or other components.
This analysis can become complex when suppliers do not provide sufficiently detailed information on materials, components or substances used.
Why should the Candidate List be monitored over time?
SCIP compliance is not a one-time exercise. The SVHC Candidate List is regularly updated by ECHA. When a new substance is added, obligations may be triggered for companies whose articles contain that substance above the applicable threshold.
In February 2026, the Candidate List was updated with two additional substances, bringing the list to 253 entries. This highlights the importance of maintaining regulatory monitoring and reassessing packaging whenever the list evolves.
What information should be requested from suppliers?
To secure compliance for cosmetic packaging, brands should request precise information from their suppliers on the materials and components used.
Key points to verify include:
- the presence or absence of SVHCs in each component;
- the concentration of SVHCs, where applicable;
- the precise identification of the article concerned;
- up-to-date supplier declarations;
- whether a SCIP notification has already been submitted;
- any changes in materials, suppliers or manufacturing processes.
This information should be updated regularly, especially after a packaging change or an update to the Candidate List.
Checklist for cosmetic brands
To assess your SCIP obligations, it is recommended to:
- Identify all packaging elements used for the product.
- Determine which elements are considered articles.
- Request SVHC declarations from suppliers.
- Check the 0.1% weight-by-weight threshold at article level.
- Confirm whether a SCIP notification is required.
- Document the information received.
- Update the assessment after packaging changes or regulatory updates.
What are the risks of non-compliance?
Poor management of SCIP obligations can create several risks for cosmetic companies:
- lack of traceability for substances of concern;
- difficulty responding to customer or authority requests;
- delays or obstacles when placing products on the EU market;
- inconsistencies in supplier data;
- REACH non-compliance risks;
- negative impact on sustainability and product transparency strategies.
For brands operating across multiple markets, packaging data management is becoming a strategic issue. Regulatory requirements related to substances of concern, materials and packaging circularity are becoming increasingly important in Europe.
How can EcoMundo support you?
EcoMundo supports cosmetic companies in assessing their regulatory obligations related to chemical substances, packaging and access to the European market.
Our experts can help you:
- identify packaging components concerned;
- analyze supplier data;
- verify the presence of SVHCs;
- determine whether SCIP notification is required;
- structure supplier information requests;
- implement regulatory monitoring adapted to your products.
SCIP compliance should not be treated as an isolated formality. It is part of a broader approach to substance control, packaging traceability and regulatory compliance on the European market.
Would you like to check whether your cosmetic packaging is subject to SCIP obligations?
