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- REACH 2018: How to get in contact with your co-registrants
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REACH 2018: How to get in contact with your co-registrants
Once you know which substances you need to register by the 31 May 2018 deadline, you need to start looking for the other companies that intend to register the same substances as you. You will need to work together to share data and prepare a joint registration. Three companies share their tips on how to find your co-registrants.
Barbara Maresta, Eigenmann and Veronelli:
The first step is to check which of the substances that you pre-registered you still want to to use in the future, what their import volume or produced tonnage is and their precise substance identity.
The second step is to check whether they have already been registered or not. If the substance has been registered, you have to contact the lead registrant, determine that the substance is in fact the same as yours and then start discussions on the substance information exchange forum (SIEF) agreements.
Sigrídur Ingimarsdóttir, Haldor Topsoe:
If your substance is not yet registered, go to REACH-IT and see who intends to register your substance. You can see all the pre-registrants in the pre-SIEF page of REACH-IT. Contact the other pre-registrants or the SIEF Formation Facilitator (SFF) to get your pre-SIEF active.
Marc Cremers, KBM Master Alloys B.V.:
If no SIEF facilitator exists, send an email to all pre-SIEF members asking for their registration intentions and what work they are prepared to do for the joint registration.
It is very important to find those companies interested in registering, because you can only proceed by yourself if none of the other pre- SIEF members are interested (one substance, one registration principle of REACH).
Small and medium-sized enterprises (SMEs) should not be scared about contacting big companies. It is important to know what your duties and rights are, and what needs to be done to complete all the activities and phases of REACH registration. When you contact the lead registrant, they have to reply to you - it's their responsibility.
Sharing activities within the SIEF
Make sure that you know the requirements and have a good understanding of the whole registration path ahead. Get to know the intentions of your co-registrants and what kind of experience and knowledge they have. Have an open dialogue, but also remember to respect competition law. Decide on how you will share the work and cost upfront. You can contact your industry organisations for advice.
Share the activities step-by-step. Make a strategy for your registration. When preparing a dossier in the past for a substance not registered, we worked with a few other companies for nearly two years, comparing our analytical data on the substance and checking the impurities. We started very early to complete the registration dossier on time. We were not the lead registrant, but we worked very closely with them. We had a common interest to do things on time and in a good manner.
For several of our substances that have not yet been registered, we are working with a consortium that does the work for us, the REACH orphan substances consortium. The consortium is managed by an experienced REACH consultant. Basically, what we do is attend meetings, gather the information from our own company and vote on the choice of technical service provider, for example, the laboratory that will do the analytical testing.
Mr Cremers, Ms Ingimarsdóttir and Ms Maresta. Copyright owned by the portrayed.
- REACH 2018 phase 2
- Getting started with EU chemicals legislation
- Chemical safety in your business
- ECHA term
Interviewees' top tips for SMEs:
Did you know?
Eigenmnd Veronelli SpA is a distributor and producer of fine, specialty and performance chemicals. Serving its main markets in Italy, Spain, Portugal, Russia and Turkey, Eigenmann and Veronelli offers chemical products and services to a wide variety of industry's needs.
Haldor Topsoe is a Danish catalysis company founded in 1940. It is a world leader in catalysis and surface science. The company has over 2 700 employees all over the world of which 2 100 work in Denmark.
KBM Master Alloys B.V. is a producer of master alloys. Production takes place in two metallurgical plants in the Netherlands.
Interviews by Hanna-Kaisa Torkkeli
Top image: REACH 2018 banner by ECHA
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