Saturday, August 27, 2011

ECHA urges registrants to verify compliance with data sharing and joint submission obligations

The Agency has noted that for some substances companies have submitted registrations possibly without taking part in a single SIEF. Registrants who find themselves in this situation are strongly encouraged to verify their compliance with data sharing and joint submission obligations. Registrants may approach the ECHA Helpdesk to obtain the contact details of other registrants for their substance.

Under the REACH Regulation, companies have to share existing information on the same substance and submit one joint dossier. Compliance with these obligations has to take place before registration dossiers are submitted to ECHA, and is facilitated through the SIEF and inquiry processes.

However, in some cases the pre-SIEF and SIEF formation process may not have worked as expected, and multiple separate (joint) registrations for the same substance have been submitted. This can be seen from some duplicate entries in ECHA's dissemination portal.. As registrants in these situations may be found in breach of the REACH Regulation, ECHA strongly encourages the registrants concerned to verify compliance with their data sharing and joint submission obligations and remedy any deficiencies as soon as possible.

To support registrants in ensuring compliance, ECHA now facilitates contact between existing registrants in the event that the contact details cannot be found via the normal channels, ie. the (pre-)SIEF or inquiry process, as appropriate. If companies become aware that other separate (joint) registrations exist for their substance, they can contact the ECHA Helpdesk to obtain the contact details of these other registrants, subject to the verification of certain information. Note that this process is only recommended to registrants who become aware of other registration of the same substance outside of their SIEF and/or joint submission (e.g. via the dissemination portal).

This new service is open to all companies that have submitted a registration for their substance(s) to ECHA and received a registration number. In order for a request to be processed, it is mandatory to indicate the registration number and the related submission number. ECHA will then provide the requester with the contact details of other registrants of the same substance as the requester via REACH-IT. In turn, these other registrants will be informed of the identity of the requester and the fact that their contact details have been passed on. If a third party representative has been appointed, ECHA will only disclose the contact details of that representative.


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