Manufacturers and importers must collaborate when they manufacture or import the same substance. That’s a stipulation of REACH. After the first step identifies a substance, the second step involves finding co-registrants, ensuring the sameness of the substance, and organizing a Substance Information Exchange Forum (SIEF). The initial task is to clarify if the substance has already been registered. Registrations can be checked at the Website of the ECHA.
If the substance has been registered, the SIEF has already organized shared use of the data. Get in touch with the lead registrant or SIEF manager and make sure that your substance corresponds to the one previously defined by the SIEF as a joint registration object. Then discuss permission (Letter of Access) to use the joint data along with the scope and the costs of such use. The calculation and share of costs must be transparent, fair, and nondiscriminatory.
If the substance is not yet registered, preregistrants must collaborate and ensure that they actually want to register the same substance. Contact information for the other preregistrants can be found in REACH-IT. They must also agree on who will take the lead in the registration process. This Webinar can be helpful here.
KFT supports companies with the registration of substances in the context of forums for the exchange of information on substances (SIEF). We handle management of the project; financial processing; trustee services; and communication with customers, official agencies, and competitors. Please contact us at email@example.com.