Companies planning to register a substance have a duty to inquire with ECHA whether a registration has already been submitted for that substance.
Similarly, ECHA should be informed through inquiry of additional information required to update a registration due to a tonnage band increase. However, if no additional information is required for an update of a registration, an inquiry should not be submitted.
To submit an inquiry, potential registrants need to prepare an electronic inquiry dossier. When preparing the dossier, specific attention should be paid to the substance identity information. This information must be complete and clearly describe the manufactured or imported substance.
Potential registrants (Article 26) and existing registrants requiring additional information (Article 12(2)) need to wait for the result of the inquiry before submitting the registration or starting any tests on vertebrate animals.
Based on the information provided in the inquiry dossier, ECHA directs inquirers to the relevant Co-Registrants page in REACH-IT where they can find contact details of other registrants and potential registrants of the same substance. For most already registered or successfully inquired substances, this is done based on the provided numerical identifiers.
In contrast, for substances where no registrants or potential registrants exist, or with ambiguous identifiers, ECHA verifies the substance identity information. If ECHA is able to conclude on the substance identity of the inquired substance, the Agency directs inquirers to the relevant Co-Registrants page in REACH-IT.
By doing so, ECHA puts potential registrants and previous registrants in contact with each other to share data and to submit a joint registration. In the co-registrants’ page in REACH-IT, the following information will be available to the potential registrant:
- Contact details: names and addresses of the previous registrants and, if appropriate, other inquirers (potential registrants).
- Studies: a list of submitter’s contact details for each endpoint and the UUIDs of the (robust) study records which have been submitted more than 12 years earlier. This information enables the potential registrant to request the sharing of existing data from the previous registrants.
While ECHA directs inquirers to relevant co-registrants, it is still the responsibility of potential registrants and previous registrants to discuss on substance sameness and to decide whether their substances can be registered together. If there is a disagreement, potential registrants can contact ECHA on substance sameness by using the webform from ECHA’s website.