The requirement to share data between companies registering the same substance is one of the fundamental aspects of the REACH Regulation. By doing this, registrants can reduce the costs and avoid unnecessary testing, especially on vertebrate animals.
The third step towards successful REACH registration is getting organised with your co-registrants. How this is done depends on whether the substance is already registered or not.
Does your organisation represent companies that deal with chemicals? Is it a non-profit or public interest organisation? If so, help us communicate about the last registration deadline - join the REACH 2018 Communicators' Network
Practical advice for new SIEFs - how to work together
Once you have found the right co-registrants for your substance, you need to agree on how to work together to share the responsibilities and costs of registration. Keep in mind that the organisation and progress of the SIEF is the shared responsibility of you and your co-registrants.
Joining an existing SIEF? Practical advice for your data-sharing negotiations
When you join an existing SIEF, you need to negotiate for access to data and how to take your share of the costs. You and your co-registrants must make every effort to reach an agreement on how to share data and its costs in a fair, transparent and non-discriminatory way. This is the key principle for data-sharing negotiations.
Making every effort means, for example, asking questions to make sure that the price of data is fair and reflects the information needs; requesting clarifications when there are misunderstandings; and solving disagreements with valid arguments.
The data-sharing dispute should only be used as a last resort when your data-sharing negotiations have failed. Before filing the dispute to ECHA, you need to make sure that you have made every effort to reach an agreement.
The dispute procedure is free of charge and you can manage it without legal support. Remember to keep the communication channels open and continue negotiating once you have filed a dispute or even when you have received ECHA's decision.
The new Implementing Regulation of the European Commission on joint submission of data and data sharing defines more clearly what the terms ‘fair, transparent and non-discriminatory' mean for data sharing. It also gives ECHA the mandate to make sure that all registrants of the same substance are part of one joint registration. The regulation entered into force on 26 February 2016.
Following the Implementing Regulation, you are no longer able to submit your registration dossier separately if a registration for the same substance already exists.
If your registration is not in line with the joint submission obligation, it will be rejected at the ‘business rules' step of your REACH-IT submission and you will be instructed to cooperate with the existing registrants of the same substance and submit jointly.
Need some hands-on training on the IT tools? Want to ask questions about REACH 2018? Take part in our Stakeholders' Day on 24 and 25 May 2016 in Helsinki. It is your chance to hear the latest news and updates from ECHA, European industry associations and NGOs. Participation is free of charge. Reserve your seat now.
Sharing data for a joint REACH registration requires negotiating for access to data in an existing registration dossier or with companies preparing a new one. Find out how small and medium-sized companies (SMEs) can succeed in their negotiations.