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The last issue of ECHA Newsletter was published in September 2020. For latest news, please go to echa.europa.eu/news.
REACH 2018: How to get organised with your co-registrants
Do you need to register a substance before 2018? Have you already found other companies that have registered or will register the same substance as you? The next step is to get organised with your co-registrants and work together to share data and its costs.
We interviewed two companies who have experience from the previous deadlines of working in a substance information exchange forum (SIEF), splitting the work and costs.
How did you start cooperating? Did you join an existing SIEF or form a new one?
Samantha Schiavon, KAO Chemicals:
We have experience of both. For substances already registered we joined an existing SIEF, got in contact with the lead registrant and after approximately six months received the information we needed to prepare our registration.
In other cases, my company has been the lead registrant. We have contacted other companies to identify potential co-registrants and get the available safety data.
Jörg Blumhoff, Organica:
To register a very important raw material, we joined an existing SIEF. The initial contact was very easy and the lead registrant replied very quickly. Along the way, communication was not very effective, but we succeeded in registering our critical substance together with six other companies.
Did you split the work between the members of the SIEF or did you rely on the lead registrant to do it all? Did you outsource any work?
Ms Schiavon:
For us, the most common practice is to manage everything as the lead registrant. It's better and easier to organise the work rather than to split it.
As for using external help, yes, we outsourced some of the work on assessing risks.
Dr Blumhoff:
We joined the SIEF as a member, so there was little work to be done. Basically, the information, the data and the letter of access (LoA) were provided by the lead registrant and we just had to pay for it.
To help with our registration tasks, we worked with consultants and laboratories.
How did you share the costs?
Ms Schiavon:
We shared all costs between the members of the SIEF for the new safety data that we needed, the administrative work and the work outsourced.
Dr Blumhoff:
In one SIEF costs were split equally in relation to the tonnage band registered. So, as a small company producing substances between 1 to 10 tonnes per year, our cost was, of course, cheaper than for the other companies.
At the end of the day, joining an existing SIEF and getting our substance registered was a good experience.
In view of the 2018 deadline, do you expect new members to join the SIEFs you are in?
Dr Blumhoff:
Yes, I expect new members to join the SIEFs we are in at the moment. Our resources do not allow us to be lead registrants in these SIEFs, so I do not think we have to prepare anything for the newcomers.
For some SIEFs, where there's no communication at present, but which will end up being very important for us, we will probably have to contact the other SIEF members to see if they really want to register the substance. If there is no reaction, we will have to register those substances by ourselves.
***
Read also our top tips for the upcoming REACH 2018 deadline, which is in many ways different from the previous registration milestones.
 | ECHA's top ten tips for 2018 registrants A lot can be learnt from successful registrants. However, we expect that the 2018 registration deadline will be different: there are many inexperienced and/or small and medium-sized companies registering; the SIEFs will be smaller; and there is a lot of new data to be shared, generated and documented. The new Implementing Regulation on joint submission of data and data sharing is expected to guide companies better on how to fulfil their REACH requirements. We share with you our top tips for REACH 2018 on how to get organised with your co-registrants: 1. Get in touch with your co-registrants through the pre-SIEF page of REACH-IT. Other registrants may have used other identifiers for the same substance, so widen your search by using the ‘related substances' option. 2. Take the initiative in SIEFs that are crucial for your business, especially when no other SIEF member seems to be willing to move ahead. 3. Make sure that you discuss substance sameness before you start sharing data. This way you will spend your time and money on the right substance from the very beginning. 4. Focus your discussions on getting things done in the SIEF – and if you cannot agree on how to distribute work among the SIEF members, consider hiring a consultant. Act in time and establish a timeline for your registration. 5. Provide the information needed to move on with the preparation of the joint registration dossier without unnecessary delays. 6. Make use of the material and IT tools that ECHA has developed to help you to comply. Bringing a dossier to an acceptable quality level only after it has been submitted may be inefficient and costly. 7. Sharing data is not meant to create profit for anyone, but to share the actual costs between all co-registrants. If you start to prepare a dossier for 2018, establish a robust cost sharing model. If you join an existing registration, request a breakdown of the costs and only pay for the data you need to satisfy the information requirements relevant for your registration. 8. Keep track of all communication between SIEF members. 9. Treat the company/person you are negotiating with as you would expect to be treated. 10. Remember that preparing a registration is a shared and individual responsibility of all co-registrants. If you are not the one doing the work, check regularly to make sure that it is really progressing. |
Further information:
- REACH 2018 phase 3: Get organised with your co-registrants
- Support web pages for registration
- REACH 2018 - step-by-step advice
- Terminology - in 23 languages
| | Kao Chemicals Kao Chemicals Europe (KCE) is the European branch of the Kao Corporation Japan. Kao Japan is known on the Asian market as a producer of cosmetics and household products, but also has a large chemical branch. KCE has its origins in surfactant technology and deals with products that are, for example, for the personal care, laundry and cleaning, and technical application markets. The implementation of REACH is organised centrally by the KCE Product Safety department. Five of its members are working full time on REACH. |
| | ORGANICA Feinchemie GmbH Wolfen ORGANICA is a small fine chemical company, specialising in hazardous chemical reactions and focused on the exclusive synthesis of fine chemicals. The company offers customised synthesis of advanced organic intermediates for major pharmaceutical and industrial companies around the world. |
Text by Anca-Mirela Petrisor
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