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A third party can create an ECHA account to submit data to the SCIP database on behalf of a duty holder. A link between the third party and the duty holder accounts can be made using the foreign user functionality in ECHA Accounts: the agreement reached between both parties is based on intra-party arrangements.
A foreign user can perform actions on behalf of the company that grants him or her permission to use an account, through an appointment made by the company’s Legal Entity manager, from their own ECHA account. For more information, please consult Q&A 960. Practical details on how to set up a foreign user link can be found in the chapters “User roles” and “How to add a foreign user” of the ECHA Accounts manual.
A foreign user needs to pay special attention to changing to the duty holder account before a notification to the SCIP database is made.
Duty holders will remain responsible for the notifications submitted to the SCIP database: since a notification must be submitted using the duty holder account, a duty holder can verify at any time the list of notifications submitted to the SCIP database. Duty holders that establish a foreign user link give visibility to the content of their account based on the roles selected. In addition, duty holders can remove the foreign user link at any time.
a. The submission is made using the same ECHA account; and
b. The same primary article identifier (type and value) is part of your dossier.