Collaborate with your co-registrants

Collaborate with your co-registrants

All co-registrants have a shared responsibility to keep the jointly submitted information of the registration up to date. It comprises of information about the physico-chemical, toxicological and eco-toxicological properties of the substance, classification and labelling, and guidance on safe use.

If the update is concerning jointly submitted information, it is the responsibility of the lead registrant to update the registration on behalf of the members of the joint submission.

You need to have a collaboration agreement in place to manage the work. In addition, some of the updates might lead to new costs, so you need to have a mechanism to agree with your co-registrants on how these costs are shared.

The jointly submitted data must be updated, in IUCLID format, for example in the following cases:

  • You become aware of new hazardous properties for the substance, for example, during the regular literature review or following the communication of new information by a customer.
  • A jointly submitted CSR needs to be updated, following the identification of new uses or uses advised against for the substance.
  • The classification and labelling of your substance changes, for example as a result of changes in the Classification and Labelling Regulation (CLP) or when new information on the hazardous properties become available.
  • A company in the joint submission increases their production volume and moves to a higher tonnage band. If the information needed for registration in the higher tonnage band is not yet available in the joint submission, it will need to be generated and included in the dossier. The co-registrants have to agree on the approach. At the very least, you have to ask all registrants in the joint submission if they have any relevant information or also intend to move to a higher tonnage band.
  • ECHA or a Member State request additional information from the co-registrants during dossier or substance evaluation. The co-registrants to whom the decision is addressed, need to agree on the approach on how to fulfil the request.