QWhich suppliers of articles have the obligation to provide information to ECHA?
The following suppliers of articles need to provide information to ECHA:
-EU producers and assemblers,
-EU distributors of articles and other actors who place articles on the market.
Retailers1 and other supply chain actors supplying articles directly to consumers are not covered by the obligation to provide information to ECHA.
According to Article 3(33) of the REACH Regulation, the supplier of an article means ''any producer or importer of an article, any distributor or other actor in the supply chain who places an article on the market".
The obligation to provide information to ECHA starts with the first supplier (producer/importer2), because they have or should have the best knowledge of the article. Concerning other suppliers further down in the supply chain (such as distributors who are not importers), a pragmatic approach may be sought as regards to the way they fulfil their obligation, such as making reference to information already submitted by the upstream supplier. Such an approach would avoid double reporting and thereby limit unnecessary administrative burden for both duty holders and authorities.
1 Excluding retailers who are importers and/or producers.
2 Including distributors who are also importers.
(source: Commission non-paper on the implementation of articles 9(1)(i) and 9(2) of the revised Waste Framework Directive 2008/98/EC, distributed to the CARACAL and Waste Expert Group in June 2019, ref. Ares(2019)3936110).