Raj Takhar: While an EU-based importer may perform SCIP database submissions, in practice they may be unwilling or unable to perform these tasks. An EU importer may set up contractual agreements with their non-EU article suppliers to act on their behalf (as a “foreign user”) with regard to SCIP database submissions. However, the responsibility for the SCIP notification and its content still lies with the EU article importer. Please be aware, third-party users (“foreign users”) will see the same information as all other users in the European Chemicals Agency (ECHA)’s IT Tools. It is also worth noting SCIP database submissions must go beyond REACH data requirements. The REACH Regulation was implemented primarily to enable downstream article users to be aware of the presence of any Substances of Very High Concern (SVHCs) in products, allowing them to take appropriate safety measures. To that end, the EU REACH Regulation requires companies provide (at a minimum) basic information about an SVHC present in an article above the 0.1 percent weight by weight (w/w) threshold to users of the article. The reporting requirements are much more complex for the SCIP database. Mandated under the EU WFD, the SCIP database is intended to help end-of-life waste stream operators identify articles containing SVHCs over that same threshold. By the time a product enters its end-of-life phase, it is possible a significant amount of time will have passed since a REACH declaration was last received by a consumer. The SCIP database thus seeks to enable progress towards the EU circular economy, since the presence of SVHCs is seen as a major hindrance to this goal. The SCIP database requires a granular-level of data collection analysis, which extends throughout the supply chain for products destined for the EU market, regardless of where they were manufactured.