Question: Are resellers in scope of the EU Waste Framework Directive? Do I need to make a submission to the Substances of Concern In articles, as such or in complex objects (Products) (SCIP) database for any products that contain SVHCs?
Answer: If the supplier that provides you these goods is located outside of the EU, then the submission requirements fall on the party that imports and distributes the article (product) in the EU. If you are that party, then you will have a legal obligation to submit a product dossier to the SCIP database.
If your supplier is located within the European Economic Area (EEA), the supplier is the “duty holder,” and retains the submission requirement. However, you still need to make a Simplified Submission Notification (SSN) using the product’s SCIP identification number and article data (in an Excel file), which must be provided to you by your supplier. This process means:
- Submitting the data acquired from your supplier to the ECHA Submission Portal.
- Receiving a unique, supplier-specific identification number for the SSN.
This is a time-intensive task for resellers with large product catalogs, although the ECHA is evaluating simpler methods to manage the data.
Article is current as of 2020-08-07.