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Phase 3 of REACH 2018
Work together to share data and its costs
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.
Press release (translated) | REACH 2018 phases | Registration support
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Get organised - how to start
As a potential registrant, you can face two situations:
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If no registration for your substance has yet been submitted, you need to get organised with other potential co-registrants and prepare the joint registration.
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If a joint registration already exists, you need to contact the existing registrants and agree to join them. In this case, it is likely that the preparatory work has already been done.
Working together with your co-registrants | Factsheet: SIEF, data sharing and joint submission
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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.
Practical advice for new SIEFs - how to work together
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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.
Practical advice for data-sharing negotiations | Factsheet: Typical cost elements in data-sharing negotiations
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Filing a data-sharing dispute - the last resort
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.
Data-sharing disputes in practice
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REACH data-sharing principles clarified
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.
News alert | EurLex
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One substance, one registration
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.
News alert 25 Jan | News item 27 Jan | Strengthening the OSOR principle [PDF]
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Save the date - ECHA's Stakeholders' day in May
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.
More | Register
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Practical tips & case studies |
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Interview
Know your rights when negotiating for data
 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.
ECHA Newsletter
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Practical advice
How to get organised with your co-registrants
 Two companies share their experience from
the previous deadlines of working in a substance information exchange forum (SIEF), splitting the work and costs. Read also ECHA's tips for 2018 registrants.
ECHA Newsletter
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Follow, like and share in social media
Are you active in LinkedIn? Follow our pages dedicated to the REACH 2018 deadline to keep up-to-date with relevant news. Invite your friends and colleagues working with chemicals to follow it too.
In Twitter, you can easily find our REACH 2018 related tweets by searching for the hashtag #REACH2018. Retweet and follow @EU_ECHA.
LinkedIn for REACH 2018 | Twitter #REACH2018
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