ECHA

To support potential and existing registrants to better fulfil their REACH obligations on data shar­ing and joint submissions, ECHA has developed a new functionality in REACH-IT.

Multiple registrants of the same substance share two main obliga­tions under the REACH regulation: data sharing and joint submission.While the Regulation provides a framework for interaction between registrants, it does not recommend any particular means of coopera­tion.

At the end of November 2012, ECHA will release an update of REACH-IT, which will help.

 

WHO CAN BENEFIT FROM THIS NEW FUNCTIONALITY?

ECHA will put in contact companies that either received a valid registra­tion number or an inquiry number. Consequently potential registrants that did not successfully inquire or previous notifiers under the Directive 67/548/EEC that did not claim their registration number to ECHA will not benefit from this new functionality.

 

DIRECT ACCESS TO THE CONTACT DETAILS OF YOUR CO-REGISTRANTS

The new functionality will enable companies to access the contact details of existing registrants within REACH-IT. A new page, the Co-registrants page, will provide access to the identity and contact details of other existing registrants (or of their Third Party Representative, or TPR) for substances with the same numerical identifier. So, registrants can see who else has registered their substance and therefore shares obligations under REACH.

 

ROLES IN JOINT SUBMISSION VISIBLE

The role of the registrants within the joint submission will also be visible. To support companies to further improve their compliance with the joint submission obligation, the Co-registrants page will display which legal entity is the lead registrant or a member of a joint submission. In addition, legal entities which have submitted within different joint submissions or even outside of any joint submission will be visible to the other registrants.

 

MAKE SURE YOU ARE PART OF A JOINT SUBMISSION!

ECHA urges all registrants to use this new functionality to ensure compliance with their obligations. For example, a registrant that has submitted their registration out­side an existing joint submission is required to contact the lead regis­trant. Both parties share a common responsibility to make every effort to ensure that they are part of the same joint registration dossier.

 

ENSURE YOUR CONTACT DETAILS ARE CORRECT AND CAN BE DISPLAYED

The identity of the nominated TPR of (potential) registrants will be automatically extracted from section 1.1 of the IUCLID dossier. ECHA strongly recommends that existing registrants and potential registrants that made successful inquiries check the consistency of the information they have submit­ted in their dossiers (registrations, inquiries etc.) to avoid their own company information from being unexpectedly disclosed. In the specific case of notifications under Directive 67/548/EEC (NONS), whether claimed under REACH or not, ECHA advises the owner to assess whether their identity needs to be protected.

Companies who want to amend their dossier(s), for example to introduce updated TPR contact de­tails or join or merge existing joint submissions, will need to update their registration dossier before the end of November 2012.

 

INQUIRY PROCESS STREAMLINED

The next REACH-IT release will also enhance the inquiry process. The main requirements to prepare and submit inquiry dossiers will not be affected. However, registrants will be asked to specify their registra­tion intentions, with regards to the expected registration date. Once ECHA has identified the substance and processed the inquiry to an end, the Co-registrants page will then provide direct access to the identity and contact details of the potential and previous registrants, so that inquirers are put imme­diately in touch with their fellow registrants.

Successful inquirers will access the same information related to other po­tential and existing registrants. Hav­ing said that, any potential difference in company details between inquiry and registration dossiers will become automatically visible to all co-regis­trants and potential registrants.

So the important benefit for the inquirers is to get up-to-date and real time information using REACH-IT. This is a major improvement to the existing procedure where ECHA sends the contact details in a paper format, reflecting the status at the sending time. ECHA will continue to improve its technical completeness check plug-in tool (TCC), so that potential registrants can increase the overall quality of the dossiers they submit and increase the success rate of their submissions. These enhancements are expected to shorten the time for succesful inquirers to get the infor­mation necessary to register.

 

VISIBILITY OF ENDPOINTS' DATA

The REACH-IT Co-registrants page will display the endpoints' data requested as part of an inquiry or a request for further information about a substance. This aims to facilitate data sharing between potential and existing registrants.

 

WHAT INFORMATION CAN I ACCESS ON THE CO-REGIS­TRANTS PAGE?

The Co-registrants page provides different information according to the status of the registrants:

• Registrants can see the roles of all co-registrants, i.e. wheth­er they are lead or member, of one or different joint submis­sions. Registrants can also view the potential registrants that successfully inquired.
• Potential registrants, during the 12 months following their successful inquiry, can see all registrants but only the leads are marked.
• Potential registrants, beyond the 12 months of their suc­cessful inquiry and if they have not yet registered, will have limited visibility.

 

FURTHER INFORMATION

Web page on inquiry, with links to supporting material

Webinars on substance identifica­tion, inquiry and data sharing (November 2011, January 2012 and March 2012)

Two-week interruption of the inquiry process in November (News alert, 25 September 2012) 

ECHA advises registrants to check their company information in REACH-IT (News alert, 17 October 2012) 

Presentation during the Lead reg­istrant workshop (11-12 October 2012, Helsinki)

Web page on data sharing, with links to supporting material

REACH-IT

Text by Laurence Hoffstadt