The responsibility for fulfilling the requirement of providing information to ECHA lies with the EU importers. The following types of companies (suppliers of articles) throughout the supply chain will need to submit information into the SCIP database:
EU producers and assemblers
ECHA has stated that retailers, and other companies who are supplying articles directly to consumers will not have to submit information on 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 requirement to provide information to ECHA starts with the first supplier (producer/importer (including distributors, who are also importers), 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.
Companies outside of the EU are not subject to this obligation and are not allowed to submit SCIP notifications.