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Compliance with REACH - a service from the ITIA

General Information

All potential registrants of existing (phase-in) substances who pre-register the “same” substance will be automatically included in a SIEF for their respective substance.  Our web-based forum aims to assist the identification of the companies that register the “same” substance and enable the exchange of test data.

i) Joint Submission

Each company must register its substances individually (ie company name, identity of the substance and information on manufacture and use, together with contact details and tonnage bands).  However, REACH requires the registrants of the same substance to submit the following sections of the technical dossier jointly:

  1. classification and labelling of the substances
  2. study summaries and, if required, robust study summaries
  3. proposals for testing

The joint submission requires that the registrants work together on the preparation of the technical dossier.  There will be one technical dossier for each substance which will be submitted by the Lead Registrant of the relevant SIEF.

Refusal to submit the registration dossier jointly with other potential registrants is only possible if:

  1. it is disproportionately costly for the specific registrant
  2. the registrant needs to prevent disclosure of commercially sensitive information
  3. the registrant disagrees with the Lead Registrant on the selection of the information

Companies wishing to opt out from a joint submission must bear in mind that their solo registration dossier will be examined by ECHA as a priority and they will have to pay higher registration fees.  In addition, such companies will not be exempt from the obligation for data-sharing.

ii) Data Holders

As provided by REACH, a data-holder, e.g. a downstream user, a manufacturer and/or importer of the substance in quantities below one tonne per year, a research centre, university laboratory, may offer a study or test to SIEF participants, but cannot themselves request data.  If they are asked to provide data by the SIEF members, they must provide it for appropriate compensation if such data is used to support the registration.