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REACH 2018 Find your co-registrants and prepare to register jointly.

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Presentation on theme: "REACH 2018 Find your co-registrants and prepare to register jointly."— Presentation transcript:

1 REACH 2018 Find your co-registrants and prepare to register jointly

2 Purpose of this presentation
This presentation, with notes, was prepared by ECHA, the European Chemicals Agency, to assist you in preparing a presentation about REACH 2018, i.e. the last registration deadline of phase-in substances. The intention is that you can select relevant slides and modify them as necessary to suit your audience, whether it is management, workers, environmental health and safety professionals, authorities etc. You may use it without additional permission. This presentation gives a brief overview of phase 2 (Find your co-registrants) of ECHA’s REACH 2018 Roadmap. It belongs to a series of presentations relating to REACH 2018, which are on ECHA’s website. We welcome your comments and suggestions at: Legal notice: The information contained in this presentation does not constitute legal advice and does not necessarily represent in legal terms the official position of the European Chemicals Agency. The European Chemicals Agency does not accept any liability with regard to the contents of this document. Release: May 2017

3 REACH registration 2018 Phase 2 activities
Find out if your substances are already registered Verify your pre-registrations Find and contact your co-registrants Establish substance sameness Prepare for working together in the SIEF This presentation is about guiding you in identifying companies you will be registering with jointly. There are 5 key activities in this phase of your preparations for registration.

4 SIEF – Substance information exchange forum
Cooperation of companies for joint registration of the same substance Increase knowledge on your substance Reduce costs of registration for everyone Avoid duplication of animal tests Share data on the substance and costs Pre-registration > pre-SIEF > SIEF > joint registration The REACH legislation imposes joint registration of the same substance. The SIEF is a specific cooperation form for companies registering the same substance under REACH. It is usually reflected in a formalised agreement. Cooperation with the SIEF members is necessary to agree on the data package for the registration and sharing of the costs for the data. Joint registration is beneficial for all, since data and costs can be shared and therefore costs can be reduced and duplication of animal testing can be avoided. The starting point for finding your co-registrants is your pre-registration in REACH-IT. All the companies that pre-registered the same substance by EC number, or CAS number or chemical name have access to a dedicated page in REACH-IT, where all the companies and their contact information is listed. This page in REACH-IT is called the pre-SIEF page. After the co-registrants agree that they have the same substance, the SIEF is formed, and the obligations for sharing data and replying to requests for data apply.

5 Find out if your substance is already registered
ECHA database of registered substances List of lead registrants In REACH-IT: Menu  Joint submissions  provide identifiers of your substance The first activity consists of finding out whether your substance is already registered by others or not. As a first step, you can quickly check the registered substances on ECHA’s website. Note that registered substances are added to the database a few weeks after their registration, so for very recently registered substances, you may need to check again a few weeks later. The list of lead registrants shows, in addition to the completed registrations, substances for which the lead registrant has started the registration activity by creating the joint submission in REACH-IT. You find the same information in REACH-IT, for substances that you have pre-registered. What next? If your substance has not been registered, you will need to form a new SIEF. If it is registered, you will need to join the existing one. Useful links: https//echa.europa.eu/information-on-chemicals/registered-substances NO: create a new SIEF YES: join an existing SIEF

6 Verify your pre-registration
Gives you the right to be on the market until 31 May 2018 need a pre-registration for each substance you need to register In REACH-IT make sure you can access your account: need your user name and password Starting point for co-registrants to find each other make sure your contact details are up to date Your pre-registrations give you the right to be on the market until the registration deadline, on the 31 May 2018, so it is important to verify that you have a pre-registration for each substance you need to register. You need a user name and a password to get access to REACH-IT. If you have forgotten your user name or password, follow the instructions on ECHA’s website to retrieve it. Ensure that the correct contact person is mentioned in the pre-registration and that the address is up to date. If you do not have a valid pre-registration or registration for your substance after 31 May 2017, you will need to submit an inquiry to ECHA and register your substance before you can manufacture or import it. Useful links:

7 If the substance is not registered yet
Find your co-registrants in pre-SIEF in REACH-IT Contact: by As a SIEF formation facilitator (SFF), you can indicate in REACH-IT that/where you want to find and discuss with co-registrants SIEFs may be small or you may be the only registrant On the pre-SIEF page in REACH-IT, you can find the contact information of your co-registrants. If your substance is critical to your business, you should take the initiative to start the discussions. You can also indicate in REACH-IT that you are willing to start up the SIEF formation by clicking the SIEF formation facilitator button and then you can post a message in REACH-IT for your co-registrants. You can, for example, provide information about the status of the SIEF or additional contact details, such as the address of a relevant website. It is important to be active in contacting other pre-SIEF members and responding to their s to find out who will become your co-registrants, therefore, who will join the SIEF. Be aware that not everyone who pre-registered will register, so although the pre-SIEF may be large, the SIEFs may have just a few participants. It is also possible that you will be the only registrant for the substance, so it is important to find that out early on by contacting each other and replying to s from others contacting you.

8 Substance identity profile (SIP)
Name Other identifiers (e.g. EC, CAS) Composition (boundary composition) for the jointly registered substance The SIP is the name, the identifiers, for example EC and CAS numbers and the composition for the substance that is jointly registered. For registering jointly, first you need to discuss if you have the same substance and agree on the name and identifiers to be used. You will also need to agree on what is the composition to be registered and to be linked to the data provided. The result of these discussions will be the substance identity profile.

9 Establish substance sameness
Follows from your substance identification Co-registrants determine the name of their substance according to the ECHA guidance, considering the composition and type of the substance If the name of the substance is the same, the substance is the same Together, determine the substance identity profile (SIP) and boundary composition(s) of the substance to be registered jointly Once you have identified your potential co-registrants, you need to make sure that you all have the same substance. If you have the same substance, you will need to register jointly, If you do not have the same substance, you cannot register jointly. All registrants need to check their analytical data and determine the name of their substance according to the rules described in the ECHA guidance. If your substance is already registered, a substance identity profile (SIP) should be already available. If the composition of your substance is not covered by the SIP but you nevertheless need to register jointly because you have the same substance, you can: extend the available boundary composition or if this is not possible and a different set of data is needed, add a second boundary composition can be added to the SIP.

10 Boundary composition Essentially defined in terms of identity of
constituents and their concentration ranges May also include additional identifiers e.g. for UVCB substances Can evolve over time Ensure that the composition of your substance is within the agreed boundary composition The boundary composition is essentially defined in terms of: identity of constituents, including the impurities, and their concentration ranges It may also include additional identifiers, for example, for UVCB substances the manufacturing process description needs to be provided as well. The SIP can evolve over time. For example when a new member manufacturing a substance with different concentration levels, joins the registration. Each registrant is responsible for ensuring that the data provided in the joint registration is appropriate for his specific composition and that the composition of the own substance is within the agreed boundary composition of the joint registration. Useful links: Guidance on identifying and naming substances under REACH and CLP, Appendix 3 (

11 If the substance is already registered
Check the list of registrants on ECHA’s website For your pre-registered substances, you can find the contact details of the lead registrant by searching for the joint submission in REACH-IT You may have received from the SIEF Contact the SIEF by Confirm that your substance identity fits the SIP of the joint registration

12 Take away messages Check which of your substances is already registered and which are not If your substance is not registered, you will need to form a new SIEF with your co-registrants If your substance is already registered, you will need to join the existing SIEF Get in contact with the pre-SIEF/SIEF members or lead registrant. Be active Agree on substance sameness Identify those substances for which you are alone and you have no data. Get help if these are business critical substances Support is available at


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