Question: Are contract manufacturers — companies that manufacture products according to full specifications and designs provided by another manufacturer — required to submit information to the Substances 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 onto the EU market, then SCIP database reporting requirements fall onto either the contract manufacturer’s customer or the importer bringing the product into the EU. Companies that do not directly send products to or manufacture products in the EU are not required to enter data into the SCIP database.
However, these companies (including contract manufacturers) should be ready to provide compliance information to the next level in the supply chain so that the ultimate duty holder can make an entry into the database. A contract manufacturer may need to collect and provide information on any parts where the contract allows manufacturer flexibility. While non-EU manufacturers are not legally required to provide this information (unless by the terms of sales or purchase agreements), doing so is a good business practice and provides manufacturers with a competitive advantage over other suppliers who may not be able to do so.
In some cases, a customer may ask their suppliers to enter SCIP data into the system on the customer's behalf, so the customer can simply reference the information in their SCIP dossier. This type of agreement would require a negotiation between the supplier/manufacturer and the customer.
Article is current as of 2021-02-04.