REACH 2018 – The Third Step: Coordinate with your Co-Registrants

Talk to your co-registrants about how you want to communicate and collaborate when working in Substance Information Exchange Forums (SIEF). The ECHA offers some practical tips on its Web site. The ultimate goal is to spread the work among the members of the SIEF fairly. You can also engage an external consultant for the first contact, who can correspond with all those involved and submit the registration dossiers.

If you decide not to engage a consultant, then you must select a lead registrant who is responsible for submitting the entire joint registration dossier. Only then can co-registrants submit their member registration dossiers. The member dossiers contain company-specific and sometimes confidential data on the volumes manufactured and the use of the substances.

Joint Use of Data

Before the dossiers are submitted, the members of the SIEF must decide how they will jointly use the scientific data and how to supplement missing or incomplete data. They must first discuss the relevance, reliability, and suitability of the data and select the required subset of the overlapping data. If a registration already exists for your substance, negotiate with the previous registrants on how to access the data that you need for your tonnage band. The ECHA offers practical advice on negotiating the joint use of data.

 Fair Distribution of Costs

The costs of a registration must be shared fairly. It’s important that you pay only for the SIEF information and administration that are directly related to your registration. It is inappropriate to derive profit from the joint use of data. Remember that data submitted more than 12 years ago can be used free of charge.

If you have any questions about the joint use of data and sharing the costs with your co-registrants, please contact the ECHA. It offers free support.

We have provided multifaceted services related to REACH for over 10 years. In case of any questions, please contact us under reach@kft.de.