SCIP Requirements for Contract Manufacturers

Question: Are contract manufacturers — companies that manufacture products according to full specifications and designs provided by another manufacturer — required to submit information to the Subjects of Concern In articles, as such or in complex Products (SCIP) database if they do not place products in the European Economic Area (EEA) market, and only make products according to customer-approved bills of materials or specifications?

Answer: If a contract manufacturer does not place a product directly into the EEA, then SCIP database reporting requirements fall onto either the contract manufacturer’s customer or the importer responsible for bringing the finished product into the EEA.


Article is current as of 2020-01-10.

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