Exchanging Information - The first deadline for Reach registration is approaching fast. This process requires that future registrants work together in Substance Information Exchange Forums (SIEF) in order to submit one joint registration dossier for one substance. In its efforts to make this registration process a success, Mercedes Viñas, manager of chemical regulation at Cefic, along with the Cefic SIEF working group have developed recommendations and tips in order to allow SIEFs to deliver.

Following the pre-registration phase, companies who have the intention to register the same substance are put in contact via Reach-IT system. Once the sameness of the substance is confirmed, companies can form a SIEF for that substance.
SIEF members need to nominate a lead registrant (LR) to submit the joint registration dossier on behalf of the SIEF members. The joint submission contains the main part of the technical dossier including the classification and labeling of the substance, study summaries and the proposal for further testing, if applicable. The rest of the SIEF members must still do a separate registration after signing up to the joint submission created by the LR in Reach-IT.

Recommendations For LR

Most of the recommendations for LR to kick off the activities in the SIEF should have taken place by now. Those include sending out a survey on the registration intentions of the SIEF members, establishing a system to support communication and keeping all the members of the SIEF informed. LR should have also coordinated the agreement on substance identity: indeed, the name and identity of the substance to be used for registration purposes should be agreed by all SIEF members.

Cefic recommends members of a SIEF to agree on operating rules, for example using the available Cefic model agreements.
It is extremely important to keep the SIEF regularly informed on the progress towards the joint submission, keeping communication channels open. For that, it is also advised to establish a single contact point for the SIEF and make this contact point known to all members. LRs are also advised to keep the SIEF distribution list up-to-date, taking late comers into account.

Also, the use of old versions of software for SIEF communication is preferred in order to avoid problems when opening communications.

Communicate decision on the scope of Joint submission: Article 11 of the Reach Regulation defines the information that must be submitted jointly and the information that must be submitted individually by each registrant. There is also some information for which the registrants can decide whether it is submitted jointly or separately.
The scope of the joint submission, and particularly whether the Chemical Safety Report (CSR) is done and submitted jointly, must be communicated to all SIEF members as soon as possible.
If it is not decided to do a joint CSR, this very demanding task has to be carried out by the individual registrants (for all volume bands greater than 10 tons/year).

It should be noted that the CSR may need to be updated once the outcome of the newly generated tests is available, if any. Some SIEFs may decide to prepare the CSR jointly but submit it separately. This option may facilitate subsequent updates, which can then be handled by individual registrants.
Please consult Cefic guidance on ES development and Supply chain communication for more information and start early!

The other points that the LR should pay attention to are to set up an efficient system for invoicing and payment, find out availability of data, and create a joint submission in Reach-IT.
Besides the discussions regarding data sharing and the preparation of the registration dossier, it is highly recommended that all SIEF members (even with no intention to register) are informed of the agreed classification. This will facilitate having a harmonised classification in case SIEF members have to notify the substance classification to the European Chemicals Agency (ECHA).

Once the information is available and ready, attention has to be brought to the actual submission procedure. The submission process entails a number of checks, and many submissions may not be successful in the first attempt. Therefore, it is important to make sure your dossier passes the corresponding checks (in order of appearance):

• Business rules


• Technical Completeness


• Financial check (to check that registration fee has been paid).

We insist that SIEF members don't forget to activate the confidentiality claims if they wish to prevent some data from being published! ECHA has published a manual that explains which fields of the registration dossier will be published unless claimed confidential.
Please check Cefic tips on how to overcome the business rules and available information at the ECHA website.
All SIEF members need to take into consideration future updates of the registration dossier (joint submission) that may occur beyond the registration deadline, for example: