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Waste Framework Directive - SCIP database

Duty holders

Which 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 importers, 
- EU distributors of articles and other actors who place articles on the market. 
Retailers and other supply chain actors supplying articles directly to consumers are not covered by the obligation to provide information to the SCIP database.
 
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/importer1), 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.
 
Retailers supplying articles to consumers are not covered by the obligation to communicate information to ECHA as the definition of “recipient of an article” refers to industrial or professional users, or distributors being supplied with an article, but does not include consumers (Article 3(35) of the REACH Regulation). 
 
Notes:
1 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).

 

What if I am an articles supplier from outside of the EU?

The responsibility for fulfilling the obligation of providing information to ECHA lies with the EU importers. 

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.

Who is responsible for the enforcement of this legal duty?
The obligations of the Waste Framework Directive will be transposed into the national law of each EU Member State, the enforcement of which is the responsibility of these Member States.

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