On December 12, 2020, the European Commission (the “EC”) issued a highly anticipated draft of newly revised standard contractual clauses (“new SCCs”) that may be used by European Union-based companies to safeguard data transfers of personal data to third countries, such as the US, in compliance with GDPR Art. 46(1). The release comes at a decidedly inopportune time as it follows on the heels of the Court of Justice of the European Union’s (CJEU) Data Protection Commissioner v. Facebook Ireland Limited and Maximillian Schrems (“Schrems II”) decision which casts serious doubt on the adequacy of SCCs alone to safeguard against the “high-risks” involved in EU to US data transfers. And for many data protection experts, the language of the revised SCCs only adds to the confusion, raising even more questions. But one question in particular seems to be prominent among others—for transfers to importers, directly subject to GDPR, are SCCs really necessary?