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- Tietojenvaihtofoorumiin liittymiseen valmistautuminen
Tietojenvaihtofoorumiin liittymiseen valmistautuminen
If your substance is already registered, a substance information exchange forum (SIEF) already exists. The SIEF is a specific cooperation for REACH registration, organised by the co-registrants, and usually formalised in an agreement, that was set up for the phase-in scheme transitory period.
You need to contact your co-registrants about joining the SIEF.
In the SIEF, you will share the data you have on the substance with your co-registrants, share the costs for that data (see phase 3: Get organised with your co-registrants) and prepare the joint registration (see phases 4, 5, and 6). But before, you will need to confirm that your substance is within the boundaries of the substance identity profile (SIP) agreed in the SIEF.
The steps below explain how to prepare to join an existing SIEF.
Participants of a SIEF set up their own organisation and communication methods, so some SIEFs are easier to find than others. In some cases, it may be easier for you to find the lead registrant for your substance. Although lead registrants are not necessarily the ones who take care of newcomers, they will be able to inform you on how to get in contact with the SIEF.
There are several options to find the SIEF or the lead registrant:
- For all your pre-registered substances, you can find the contact details of the lead registrant in REACH-IT (see point 3 for more details).
- A list of substances with an active lead registrant is available on ECHA’s website. This list is extracted from REACH-IT. The lead registrants are listed if they have agreed to publish their names.
- Check your email: you may already have received an email with contact information for the SIEF or the lead registrant.
- In REACH-IT, check the ‘information from the lead registrant’ in the pre-SIEF page. Point 4 explains this further.
REACH-IT is the IT tool you have to use to submit information to ECHA, including pre-registrations and registrations.
You can access REACH-IT from ECHA's homepage. You log in with your user ID and password. If you are not yet a user, you can sign up.
In REACH-IT, click ‘Menu > Joint submissions > Search and view’ to find the joint submission, using your substance identifiers (e.g. EC number). Check the box 'Show other joint submissions?' - otherwise, the search results will be limited to those joint submissions where you are already a member.
The search results will show you the contact details of the lead registrant, if you have pre-registered the substance. The substance identity profile (SIP) of the registered substance will also be shown, if the lead registrant dossier was submitted or updated after 21 June 2016.
REACH-IT contains a pre-SIEF page for each substance you have pre-registered.
You can access the pre-SIEF through the ‘Pre-registrations and pre-SIEFs’ option in the REACH-IT menu. The pre-SIEF contains the contact information of the other companies that have pre-registered your substance, and also a space where the lead registrant can post information to the co-registrants.
Check there for information on how you can join the SIEF.
If you are not yet ready to contact the SIEF but want to be informed about what is going on, it is important that your contact details in the pre-SIEF are up-to-date. Your contact details in the pre-SIEF come from your pre-registration.
You can find your pre-registrations in REACH-IT through ‘Menu > Search > Pre-registrations and pre-SIEFs’.
Each pre-registration contains contact information, normally of a person in your company or a third party representative (TPR). This contact information (name and email) is available to all who have pre-registered the substance.
Decide if you want to keep the current contact in your pre-registration or change it, and verify that the contact information is up-to-date for each substance you intend to register.
Remember that your pre-registrations are not only a starting point for getting in contact with your co-registrants, they also give you the right to be on the European market without a registration until your registration deadline.
Verify that you have a pre-registration for each substance you need to register. If you miss a pre-registration, then check what to do from the questions and answers below.
Email is generally the easiest way to contact the SIEF or the lead. You cannot contact them through REACH-IT.
Don't wait until the last minute to make contact. Be proactive!
Respond when you are contacted by the SIEF or the lead to ask about your registration intentions. This will make joining the SIEF easier.
Once you are in contact with the SIEF, you need to establish substance sameness.
For establishing substance sameness, you need to have determined the name of your substance according to the Guidance for identification and naming of substances under REACH and CLP (see also phase 1: Know your portfolio). If the name is the same as your co-registrants’, then the substances are considered the same. You will then need to make sure that your substance is within the boundaries of the substance identity profile (SIP) agreed by the SIEF. If the description of the SIP is not available in the joint submission in REACH-IT (see point 3), the SIEF will provide it.
If your substance is not within the boundaries of the SIP, you and the other participants of the SIEF will need to agree either to expand the scope of the SIP or to agree that your substance is not within the scope. Guidance on the SIP is included in Appendix III of the Guidance for identification and naming of substances under REACH and CLP.
If you have concerns about confidential business information (CBI) when discussing substance sameness, read the questions and answers below.
If you agree that your substances are the same, you join the SIEF and can start sharing data and costs to become a member of the joint registration.
Substance information exchange forums (SIEFs) have been the means to facilitate cooperation about the joint registration according to the REACH Regulation. The obligations to cooperate contractually beyond the last registration deadline (31 May 2018) remain in the form of a SIEF or similar structure.
There are two formally separate roles in the SIEF: the lead registrant and the member registrants. You will be a member registrant.
The lead registrant has already submitted the joint registration. The lead registrant will give you your security token number, so you can join the joint registration in REACH-IT.
When preparing the joint registration, the earlier co-registrants have already elected the lead registrant and decided on how to work together. This is usually documented in an agreement that you will be asked to agree to when joining the SIEF (see phase 3: Get organised with your co-registrants).
The agreement should cover the different activities that SIEF participants have to perform to register (see phases 3, 4, 5 and 6) and keep the registration up-to-date (see phase 7). These activities include the following administrative, technical and content-related work:
- SIEF administration: establishing contact points for communication within and outside the SIEF, organising the way the invoices and payments are dealt with, and developing reimbursement schemes and keeping records.
- Preparing the content of the dossier: collecting existing data, generating new data, discussing data quality, agreeing what data will be submitted jointly, negotiating data-sharing costs, performing chemical safety assessments, deriving the classification, and preparing the chemical safety report.
- Preparing the IUCLID dossier and submitting it: creating the joint registration dossier in IUCLID, submitting the dossier to ECHA and following up the invoice and messages in REACH-IT.
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