Substances of Concern and SCIP: What DPP Means for Chemical Compliance

When construction product manufacturers think about Digital Product Passports, they tend to focus on performance data and environmental declarations. But there is a third pillar of DPP data that many overlook until it becomes urgent: substances of concern.

The DPP must declare the presence of certain hazardous substances in your products. This is not a new regulatory concept - it builds on obligations that already exist under REACH and the SCIP database. But the DPP brings these chemical compliance requirements into sharper focus and integrates them with product data in a way that demands attention.

If your reaction to “substances of concern” is “that does not apply to us - we make concrete blocks, not chemicals,” read on. You may be surprised.

The Regulatory Background: REACH, SVHC, and SCIP

To understand what the DPP requires, you need to understand the existing framework.

REACH

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is the EU’s primary chemicals regulation, in force since 2007. REACH requires manufacturers and importers of chemical substances to register them with the European Chemicals Agency (ECHA) and to assess and manage the risks they pose.

REACH applies to substances, not just to chemical companies. If your construction product contains chemical substances (and it does - every product is made of chemicals), REACH is relevant.

SVHCs - Substances of Very High Concern

Under REACH, certain substances are identified as Substances of Very High Concern (SVHCs). These are substances that may have serious effects on human health or the environment. SVHCs are placed on the Candidate List, which ECHA updates twice a year. As of early 2026, the Candidate List contains over 240 substances.

SVHCs are identified based on one or more of the following properties:

CMR - Carcinogenic, Mutagenic, or toxic for Reproduction (categories 1A or 1B).
PBT - Persistent, Bioaccumulative, and Toxic.
vPvB - Very Persistent and Very Bioaccumulative.
Equivalent concern - substances with scientific evidence of probable serious effects to human health or the environment (endocrine disruptors, for example).

If your product is an article (which construction products are, under REACH’s definition) and it contains an SVHC from the Candidate List at a concentration above 0.1% by weight (w/w), you have obligations.

SCIP - The Database for Substances of Concern in Products

Since January 2021, companies supplying articles containing SVHCs above the 0.1% threshold on the EU market must submit a notification to the SCIP database, operated by ECHA. SCIP stands for Substances of Concern In articles as such or in complex objects (Products).

SCIP notifications include:

Identification of the article (name, identifiers, categorisation).
The name and concentration range of the SVHC.
Where in the article the SVHC is located (at the component level for complex articles).
Safe use instructions.

SCIP was designed to ensure that information on SVHCs in products is available throughout the product lifecycle, particularly to waste operators. The database is publicly accessible, and any article containing an SVHC above 0.1% should have a SCIP notification.

How Construction Products Are Affected

The question is not whether your construction products contain chemicals. They do. The question is whether they contain SVHCs above the 0.1% threshold.

Here are common scenarios in the construction sector:

Flame Retardants

Many construction products require fire performance - insulation, cables, sealants, cladding, and composite panels. Brominated flame retardants have been widely used and several are now on the SVHC Candidate List. HBCDD (Hexabromocyclododecane) was one of the first to be targeted and has been largely phased out, but other flame retardants remain under scrutiny.

If your product achieves its fire classification through chemical flame retardant additives, check whether those substances are on the Candidate List.

Plasticisers

Phthalates are a class of plasticisers used extensively in PVC and other flexible plastic products. Several phthalates are SVHCs, including DEHP, DBP, BBP, and DIBP. If your products contain PVC components - flooring, cable insulation, profiles, membranes - phthalate SVHCs may be present.

The concentration threshold applies at the article level, not the product level. A window system is a complex object; the PVC profile is an article within it. If the PVC profile contains a phthalate SVHC above 0.1% w/w of that profile, it triggers the obligation, even if the phthalate is a tiny fraction of the total window weight.

Heavy Metals in Pigments and Stabilisers

Lead, cadmium, and their compounds are SVHCs that historically appeared in pigments, stabilisers, and coatings. Lead chromate pigments (used for yellow and orange colours) are Candidate List SVHCs. Lead stabilisers in older PVC formulations are another source.

If you manufacture coloured products or products with PVC components, check the pigment and stabiliser supply chain.

Coatings and Surface Treatments

Construction products with factory-applied coatings may contain SVHCs in the coating formulation. Bisphenol A (BPA), an endocrine disruptor on the Candidate List, is found in some epoxy coatings. Certain isocyanates and their reaction products in polyurethane coatings are also under scrutiny.

Concrete Admixtures and Additives

Even “simple” products like concrete can contain SVHCs through admixtures. While mainstream admixtures from major suppliers are typically reformulated to avoid SVHCs, specialist admixtures, release agents, and curing compounds should be checked.

Adhesives and Sealants

Construction adhesives and sealants are chemical-intensive products. Formulations may contain SVHCs as solvents, crosslinkers, plasticisers, or other functional ingredients. This is a category where regular review against the evolving Candidate List is essential.

The DPP Requirement: Substances of Concern Declaration

The Digital Product Passport under CPR 2024 will require manufacturers to declare substances of concern present in their construction products. This requirement builds on SCIP but goes further in terms of data integration:

The DPP must identify substances of concern present above threshold concentrations.
The data must be structured and machine-readable (not a free-text statement).
The information must be linked to the specific product identified by its unique identifier (GTIN).
The data must be accessible through the DPP data carrier (QR code or other mechanism).

This means that your SCIP notification data and your DPP data need to align. If you have a SCIP notification for a product, the DPP must reflect the same substance information. If your DPP declares no substances of concern, but you have a SCIP notification on file, you have a compliance contradiction.

The Link Between SCIP and DPP Data

SCIP notifications and DPP data serve different purposes but overlap significantly:

Aspect	SCIP	DPP
Scope	SVHCs from the Candidate List	Substances of concern (potentially broader)
Threshold	0.1% w/w per article	To be confirmed per product category
Data destination	ECHA SCIP database	DPP system/registry
Accessibility	Public database	Via product data carrier
Integration	Standalone submission	Part of holistic product data

The DPP concept of “substances of concern” may extend beyond the REACH Candidate List SVHCs. The Ecodesign for Sustainable Products Regulation (ESPR) defines substances of concern more broadly, potentially including substances restricted under REACH Annex XVII, substances regulated under other legislation (biocides, for instance), and substances identified as concerning through other assessment frameworks.

For construction products, the exact scope will be defined in the implementing acts. But the SVHC Candidate List is the floor, not the ceiling.

Practical Steps: Preparing Your Substances of Concern Data

Step 1: Determine If You Already Submit SCIP Notifications

If you supply articles containing SVHCs above 0.1% on the EU market, you should already be submitting SCIP notifications. Check:

Does your company have an ECHA account and SCIP submission history?
Are notifications current and covering all relevant products?
If you have never submitted SCIP notifications, is that because your products genuinely contain no SVHCs above threshold, or because the obligation was overlooked?

Many Irish construction manufacturers, particularly smaller companies, have not fully engaged with SCIP. This is a compliance gap that needs to be addressed regardless of DPPs.

Step 2: Identify Products Potentially Containing SVHCs

Conduct a systematic review:

List all raw materials, components, and chemical inputs for each product.
Request Safety Data Sheets (SDS) from all suppliers. SDS Section 3 (Composition/information on ingredients) lists hazardous substances.
Cross-reference against the SVHC Candidate List. ECHA provides a searchable Candidate List on their website.
Pay particular attention to: coatings, adhesives, sealants, plastics (especially PVC), pigments, flame retardants, and any treatment chemicals.

Step 3: Gather Concentration Data from Suppliers

Knowing that a substance is present is not enough - you need to know the concentration. This is where supply chain communication becomes critical.

Request explicit SVHC declarations from suppliers, stating either that no SVHCs are present above 0.1%, or identifying which SVHCs are present and at what concentration range.
Be specific in your requests - generic “compliance statements” are not sufficient. You need substance-by-substance data.
For complex supply chains (particularly imported components), obtaining reliable concentration data can be challenging. Start early and be persistent.

Step 4: Structure for DPP Format

Once you have identified which products contain which substances at what concentrations, structure this information:

Product identifier (GTIN)
Substance name and CAS number
EC number
Concentration range (e.g., 0.1-1%, 1-5%)
Location within the product (for complex articles - which component contains the substance)
SVHC Candidate List entry date
Safe use instructions

This structured data becomes the substances of concern layer in your DPP.

Why “We Don’t Use Chemicals” Is Usually Wrong

This is the most common misconception we encounter. Manufacturers of concrete, stone, timber, metal, and ceramic products often believe that chemical compliance does not apply to them. In most cases, this is incorrect.

Concrete products may use admixtures, curing compounds, release agents, or surface treatments that contain chemicals of concern.
Timber products are treated with preservatives, fire retardants, and coatings that may contain SVHCs.
Metal products have coatings, platings, or surface treatments that introduce chemical substances.
Ceramic and stone products may use sealants, adhesives, or surface treatments.
Insulation products of all types - mineral wool, PIR/PUR, EPS, XPS - contain binders, flame retardants, blowing agents, or facings that may introduce SVHCs.
Composite products combine multiple materials, each potentially introducing different substances.

Even if your raw material is natural (stone, clay, timber), the manufacturing process almost certainly introduces chemical products. Each of those products has a formulation, and each formulation should be checked against the Candidate List.

Supply Chain Communication Challenges

The biggest practical obstacle to substances of concern data is the supply chain. You need information from your suppliers about what is in their products, and they need the same from their suppliers. This chain of communication can be difficult:

Suppliers may not know. Smaller suppliers or those outside the EU may not have full formulation disclosure from their own supply chain.
Confidentiality concerns. Suppliers may be reluctant to disclose exact formulations, citing trade secrets. Concentration ranges (rather than exact percentages) and standardised declaration formats help manage this.
Language and awareness barriers. Imported components from non-EU sources may come with inadequate documentation. REACH obligations apply to the EU importer, which may be you.
Evolving Candidate List. The list is updated twice yearly. A substance that was not an SVHC when you sourced a component may become one. Regular review is necessary.

Building strong supplier communication on substances of concern is an investment that pays off across multiple regulatory requirements - not just DPPs, but REACH obligations generally, market surveillance responses, and customer queries about product composition.

Start this work now. The substances of concern data in your DPP will not populate itself, and the supply chain conversations needed to gather accurate data take time. Manufacturers who begin these conversations today will have reliable, structured data when DPP deadlines arrive. Those who wait will face a frantic scramble for information from suppliers who are equally unprepared.