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The responsibility for fulfilling the obligation of providing information to ECHA lies with the EU importers.
Companies outside of the EU are not subject to this obligation and are not allowed to submit SCIP notifications.
Importers of articles in the EU however, need to turn to their non-EU suppliers of articles and request information that they need to fulfil their regulatory obligations, such as the obligation to provide information to the SCIP database. As a non-EU supplier of articles, you should support your EU customers by providing them the necessary information about the presence of Candidate List substances in your supplied articles.
An EU importer may set up contractual agreements with their non-EU suppliers of articles to act on their behalf (as a ‘foreign user’1), regarding the submission of data to the SCIP database. However, the responsibility of the SCIP notification and its content still lies with the EU importer of articles. Please be aware that the third party users (‘foreign user’1) will see the same information as all other users in the ECHA IT Tools. For further information see Q&A 1665.
1 A ‘foreign user’ is an external user from company B who has been appointed by the Legal Entity manager from company A to work for company A. A foreign user can perform actions on behalf of the company that grants him permission to use an account from their own ECHA account. Granting access to third party users (foreign users) will allow them to see the same information as all other users. It is important that companies agree the scope of access and how for example confidential information is handled. For more information on the ‘foreign user’, please consult Q&A 960 and the ECHA Accounts Manual.