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REACH-IT

Communication in REACH-IT

What is the difference between a submission number and a reference number?

The submission number is a unique number generated for each submission - as mentioned in Article 20 of the REACH Regulation - independently of whether it is an initial submission or an update. It is generated in REACH-IT for every submission using the format "FD123456-12". The submission number shall be used in any communication with ECHA.

The reference number is a unique number generated upon the completed submission of a dossier and it is to be used for any subsequent submission update of that dossier. The format of a reference number is:

<TYPE>-<BASE-NUMBER>-<CHECKSUM>-<INDEX-NUMBER>

As an example, let's take the reference number: 17-1234567890-49-0000, where:

  • 17 refers to the submission type. In this case a late-preregistration.
  • 1234567890 is the random unique 10-digit number.
  • 49 is the calculated checksum (variable 2-digit number).
  • 0000 is the index number.

Depending on your submission type, you may find the following numbers:

  • 01  Registration
  • 02  C&L notification
  • 03  Substance in article notification
  • 04  PPORD notification
  • 05  Pre-registration
  • 06  Inquiry notification
  • 09  Data holder notification
  • 10  Downstream user report
  • 11  Application for Authorisation
  • 12  Downstream User notification (according to REACH Regulation Article 66)
  • 13 Substance Evaluation
  • 14  Annex VI – C&L Harmonisation proposal
  • 15  Annex XV – Authorisation
  • 16  Annex XV – Restriction
  • 17  Late pre-registration
  • 18  CLP 24

This structure is in the same basic format as the other registration and notification numbers that REACH-IT will provide. 

What is the difference between Tasks and Messages in REACH-IT?

The "Tasks" tab is used to inform registrants that they need to perform certain action in REACH-IT by a specific deadline. These tasks could be for example a decision that needs to be complied with, an invoice that needs to be paid, etc.

 When a registrant is required to perform a task, it is displayed on REACH-IT home page as follows:

Clicking on the tab will display the task item and clicking on the subject line will open the task. When the task is performed, it can be marked as complete by clicking on the button "Mark as complete". Marking the task as complete ensures that it is not displayed in the tasks list.

 When a task has been read, an icon looking like an open envelope is displayed. You can also view who and when the task was read in the "Task reading history" tab. Important tasks are marked with an exclamation mark.

 Registrants can also search for older tasks by selecting "Tasks" under "I am looking for" field. See screenshot

A page with multiple search criteria is displayed and filling in these fields will enable you to narrow down the results of your search.

Message Tab

All communication between ECHA and the registrant (i.e. account holder) is done through an internal messaging system in REACH-IT. Internal messages are different from emails. They are generated either automatically by the REACH-IT system or when ECHA needs to communicate with the REACH-IT account holders concerning ECHA decisions, relevant information or feedback. These messages are delivered to the user's message box inside REACH-IT.

When ECHA sends a message to a company in REACH-IT, the unread message is displayed on REACH-IT home page as follows:

Clicking on the tab will display the unread message and clicking on the subject line will open the message. You can choose to Archive the message after reading it or you can choose to leave it as it is.

When a message has been read, an icon looking like an open envelope is displayed. You can also view who and when the message was read in the "Message reading history" tab. Important messages are marked with an exclamation mark.

Registrants can also search for older messages by selecting "Messages" under "I am looking for" field. See screenshot

A page with multiple search criteria is displayed and filling in these fields will enable you to narrow down the results of your search.

IMPORTANT: According to the Terms and Conditions of use and service of REACH-IT, messages can trigger deadlines immediately upon notification in REACH-IT. We therefore advise log in to REACH-IT regularly and to open messages immediately.

 

How do I communicate that I ceased manufacture/import ?

You can inform ECHA that the manufacture/import of a substance in your company has ceased using the functionality in REACH-IT. Menu >> Search >> Reference numbers >> click on the number >> Cease manufacture or import (button located on the top of the page).

You can cease manufacture due to the following scenarios:

  • You ceased manufacture/import due to commercial reasons according to Article 50(2) of the REACH Regulation. The registered volume in your registration is updated to zero and the status of your registration is changed to "inactive". If you restart manufacture/import of the substance, you should inform ECHA via the 'Restart manufacture or import' button available on the  reference number page in REACH-IT.
  • You ceased manufacture following a draft decision according to Article 50(3) of the REACH Regulation. The status of your registration will be changed to "Revoked". A new registration must be submitted if you wish to restart manufacturing/importing your substance.
How can I find and communicate with other members or the lead registrant in a SIEF?

Pre-registration

If you submitted a (late) pre-registration (process ended on 31 May 2017), you can find any potential registrants as part of the same pre-SIEF in REACH-IT. Pre-SIEF members should start an active communication within their respective pre-SIEF and take the necessary steps to evolve from pre-SIEF to SIEFs.

To start the communication process within your pre-SIEF(s):

  • Access your REACH-IT account.
  • Select Menu >> Search >> Pre-registrations and pre-SIEFs and select your pre-SIEF.
  • A list of the pre-SIEF members and their contact details is displayed at the bottom.

The first point of contact is the SIEF Formation Facilitator (SFF) (status marked as Facilitator). If no potential registrant volunteered as SFF, any member from the pre-SIEF should actively contribute to form the SIEF.

Inquiry

Currently the only option to get in contact with the co-registrants is via an inquiry, following which ECHA will provide you with the contact details of the lead registrant or early registrants. Once your inquiry has been assessed, a decision will be sent to your REACH-IT message box. The co-registrants page in REACH-IT will give you access to the members of the same SIEF, and the contact details of the lead registrant, if available.

Further information can be found at http://echa.europa.eu/support/dossier-submission-tools/reach-it/inquiry.

What is the next step after a business rule failure?

A dossier is accepted for processing once all the relevant business rules (BR) are satisfied.

When a dossier fails business rules, detailed information is sent through REACH-IT explaining the reason for the failure. A new submission is required depending on whether the submission is an initial or an update (spontaneous or requested).

Dissemination and confidentiality

Can the data disseminated by ECHA be used to prepare SDS?

For downstream users in a supply chain who must generate their own safety data sheets for products procured from within the EEA, the main source of information should be the supplier. Using information from the supplier will ensure that any specific, detailed information is reviewed and included as appropriate.

In addition, use may be made of publicly available information that is not restricted by copyright or any confidentiality protections. It should be noted that, as stated in ECHA's legal notice, reproduction or further distribution of the information from the registration dossiers may be subject to copyright protection and that the use of the information without obtaining the permission from the owner(s) of the respective information might violate the rights of the owner.

Moreover, the legal notice emphasises that the Agency cannot guarantee the correctness of the information in the databases and REACH does not permit the Agency to make modifications to the data provided by the owner(s) of the respective information. ECHA's legal notice can be found under this link: http://echa.europa.eu/en/legal-notice .

It should be noted that the supplier of the Safety Data Sheet is responsible for the accuracy of its contents in all cases.

Where can I see the list of registered substances?

Public access to registered substances is provided on ECHA's website, in  http://echa.europa.eu/information-on-chemicals/registered-substances

The information of the registrant of a particular substance can be found under "Administrative data".

How can I check what information in my registration dossier will be published on the ECHA website before I submit my dossier?

The IUCLID Dissemination preview plug-in simulates which information from a registration dossier will be made public on the ECHA website at: http://echa.europa.eu/information-on-chemicals/registered-substances, according to Article 119 of the REACH Regulation.

To use the tool, right click on your dossier → Dissemination preview → follow the wizard. 

Dissemination preview

Can I hide my identity in the registered substances page on the ECHA website using a third party representative?

No. The identity of the registrant will be published unless a confidentiality claim on the identity of the registrant is included in the registration dossier and the justification accepted as valid by the Agency.

A third party representative (TPR) can be used to represent potential registrants in discussions with other manufacturers, importers and downstream users on data sharing and the joint submission of data as specified in Article 4 of REACH. The identity of the TPR is not published on the ECHA website. It will only be visible in:

  • The pre-SIEF, if included in a pre-registration;
  • the potential registrants tab in the REACH-IT co-registrants page, if included in a successful inquiry notification;
  • the registrants tab in the REACH-IT co-registrants page, if included in a successful registration dossier;
  • and in the joint submission, if included during creation (lead registrant) or confirmation (member registrant) of the joint submission in REACH-IT.
When will my company details be included/updated in the registered substances page after a successful registration?

It takes ECHA up to four weeks from the date of submission to update the information received from registration dossiers.

Once a registration dossier is considered to be complete, the information from your dossier will be filtered for confidentiality, aggregated to merge the information from all dossiers in the joint submission into a single dossier and processed to provide this information in the format of the registered substances page. ECHA regularly updates the information received from registration dossiers. If your registration dossier has gone through all these steps successfully, the information from your registration dossier will be updated in the registered substances page.

You may verify the last updated date at: http://www.echa.europa.eu/information-on-chemicals/registered-substances.

In specific cases where an ‘only representative’ has included the suppliers' identity in section 1.7 of their registration dossier and no confidentiality flags have been added, ECHA understands that the registrant opted for the publication of the supplier's names.

Further information can be found in the manual Dissemination and confidentiality under the REACH Regulation at: http://echa.europa.eu/manuals

 

How is the total tonnage band calculated for registered substances published on the ECHA website?

The total tonnage band displayed in the registered substances page is aggregated data calculated from all dossiers in a joint/individual submission. Tonnage data is considered only from full registrations where the tonnage band is not claimed confidential. Tonnage data is extracted from the last year reported in section 3.2 and is the sum of the reported manufactured plus imported tonnage fields.

For those dossiers which contain full and intermediate registrations, the tonnage data extracted will be the sum of the reported manufactured plus imported tonnage fields, minus the tonnage immediately used as intermediates. Tonnage data will be summed for all dossiers in a joint/individual submission, and will be displayed as:

  • A tonnage band range, i.e., 100 000 – 1 000 000 tonnes, if no dossier contains a confidentiality claim on tonnage band;
  • Open tonnage band, i.e., 1 000+ tonnes, when at least one dossier contains a confidentiality claim on tonnage band;
  • "Tonnage data confidential", when all dossiers aggregated have claimed their tonnage band as confidential; and
  • "Intermediate use only", when only intermediate registration dossiers are to be found within the joint submission.
What information in a NONS dossier can be claimed confidential under REACH?
Additional information can be claimed confidential under REACH which was not possible to claim under NONS:
- The name of the notifier (which under REACH is considered to be part of the information contained in the safety data sheet)
- The information contained in the safety data sheet (including registration number, uses and uses advised against).
- The trade name of the substance.
- If essential to classification and labelling, the degree of purity of the substance and the identity of impurities and/or additives which are known to be dangerous.
 
ECHA will give the same possibilities for claiming confidentiality to NONS notifiers as to other REACH registrants. Therefore, should your company consider that this information should not be published on the ECHA website, despite the non-confidential character of this information in the past, you can introduce the relevant confidentiality claims. These confidentiality claims need to be properly justified and the fee for claiming this information confidential in accordance with article 119(2) will be charged. The Question and Answers on NONS have further details (including for unclaimed NONS) and can be found here.
Why doesn’t the registered substance page contain information on products in buy?

REACH applies to chemical substances and therefore the registered substance page contains information only about chemical substances. It does not contain information about chemical preparations, formed by mixing together several chemical substances, nor about articles containing chemicals. In other words, you can find information about methanol or butane, but not for example about a shampoo, cleaning products or pencils.

Why can’t I find the substance I am looking for?

If the substance you are looking for has not been registered, it is not available in the database. Substances will be included in the database within 4 – 8 weeks after the European Chemicals Agency has received a registration dossier for this substance.

REACH has three deadlines for registering substances. They are 30 November 2010, 31 May 2013 and 31 May 2018. The deadline depends on the tonnage band and the hazardous properties of the substance. About 30,000 substances are expected to be available in the database after expiry of the last registration deadline in 2018.

Can I trust the data provided in the registered substance page?

The information originates from registration dossiers submitted by companies. Companies have the obligation to provide accurate and up-to-date information in their registration dossiers. ECHA's IT systems verify that the information is complete, meaning that all the information fields required for a registration in a particular tonnage band are filled in in the dossier. However, the European Chemicals Agency (ECHA) does not verify the information before its publication on the internet. ECHA can therefore not guarantee the correctness or adequacy of the information or that the dossiers are compliant with REACH.

Where can I send questions regarding the registered substance page?
If you are a registrant, and you have questions about dissemination, please contact the ECHA helpdesk.
If you are a journalist, please contact the ECHA Press Office (press (at) echa.europa.eu).
For any other questions contact the ECHA Information Desk
 

To leave feedback, please use the feedback form on the portal.

In the case of an only representative, what name will appear on the dissemination page: the non-EU company or the only representative?

The table below defines which legal entity will be disseminated on ECHA’s webpage depending on information provided in sections 1.1 and 1.7 of your IUCLID dossier.

Further information can be found in the manual Dissemination and confidentiality under the REACH Regulation at: http://echa.europa.eu/manuals

Functionalities

Which web browsers are supported by REACH-IT?

REACH-IT has been tested with:

  • Google Chrome 48.0 and higher on a Microsoft Windows platform
  • Internet Explorer 11.0 and higher on a Microsoft Windows platform
  • Mozilla Firefox 44.0 and higher on a Microsoft Windows platform

The use of untested browsers may reduce REACH-IT functionalities and cause application errors in REACH-IT. Using an older version of the browsers, or different software platform, may cause incompatibility issues with REACH-IT functionalities. Therefore, users are advised to upgrade their internet browser as mentioned above.

Can I create a REACH-IT account for learning purposes and remove it afterwards?

No, REACH-IT does not allow, under any circumstances, the creation of accounts for the purpose of testing. The data entered into REACH-IT is binding and may trigger regulatory obligations and cannot be modified or deleted. Testing data may alter the correct functioning of the system, impact statistics and priorities, and cause harm to other registrants and notifiers who submit genuine data.

How do I sign up in REACH-IT if my company has different roles and/or acts as an only representative?

If you are an only representative (OR) who represents more than one non-EU/EEA manufacturer, you will have to register separately for each non-EU/EEA manufacturer you represent. It is not possible to have one common account in REACH-IT used by multiple legal entities. However, it is possible to use same company information (e.g. name, VAT, address, etc.). You may consider adding a numerical or other identifier to your company name when signing up in REACH-IT, to facilitate the management of different legal entity accounts.

A user with the "Legal entity manager role" can use a "Foreign user" to access multiple legal entities. More information on how to do this can be found in chapter 6.7 of the ECHA Account manual.

Note that in the "Company Size" information, you must indicate the size of the non-EU/EEA manufacturer you are representing and not the size of your own legal entity. ORs can provide different contact details for each account.

If you made a mistake when indicating the company size of your company (or the one you represent as an OR) in REACH-IT when submitting a registration dossier or after a registration number is provided to you, refer to the page related to Small and Medium-sized Enterprises on ECHA website to find out more about how to correct this mistake.

 

What format of attachments does REACH-IT and IUCLID support?

REACH-IT and IUCLID support the following file types: jpg, jpeg, pdf, doc, docx, rtf, txt, tiff, mol, png and gif.

If you attach a file, which is unsupported by REACH-IT or IUCLID, you could be contacted by the Agency with a request to update your submission.
 
Invoicing and Payments

Who sets ECHA's fees?

ECHA fees and charges payable under Regulation (EC) No 1907/2006 ('the REACH Regulation') are set by the European Commission, with the agreement of the EU Member States. They are laid down in the Commission Regulation (EC) No 340/2008 of 16 April 2008 on the fees and charges payable to the European Chemicals Agency (OJ L 107, 17.4.2008, p. 6, "the REACH Fee Regulation"), as subsequently amended by the Commission Implementing Regulation (EU) No 254/2013 of 20 March 2013 (OJ L 79, 21.3.2013, p. 7) and by the Commission Implementing Regulation (EU) 2015/864 of 4 June 2015, and are subject to regular reviews.

For more information, please consult the European Commission website: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02008R0340-20150625

What will the amount of the invoice be?

Fee amounts are specified in the Commission Implementing Regulation (EU) No 2015/864 of 4 June 2015 amending Regulation (EC) No 340/2008 on the fees and charges payable to the European Chemicals Agency ("the REACH Fee Regulation").

Information related to the chargeable confidentiality claims can be found in chapter 3.5 of the manual “Dissemination and Confidentiality under the REACH Regulation” at: https://echa.europa.eu/manuals

How will I receive ECHA's invoice?
After your REACH submission has been received by ECHA, you will receive an electronic invoice only, via REACH-IT. This electronic invoice can be downloaded from your REACH-IT account in PDF format.
When do I have to pay ECHA's invoice?

The timelines for payment of fees levied under the REACH Regulation are specified in the REACH Fee Regulation as subsequently amended by the Commission Implementing Regulation (EU) No 2015/864 (see QA 716) and the precise due date is set out in ECHA's invoice.

Fees invoiced for initial and update registrations

In the case of fees for registrations submitted, as well as in the case of updates of a registration, the initial payment due date of the fee is set at 14 calendar days from the date on which the invoice was notified to you. However, in the case of fees for registration of pre-registered substances, which are submitted to ECHA during the two months preceding the relevant registration deadline specified in Article 23 of the REACH Regulation, the initial payment due date of the fee is set at 30 calendar days from the date on which the invoice was notified to you.

If the payment has not been made within the prescribed period (by the initial payment due date), ECHA will set a second deadline for payment. This second deadline (extended due date) is usually up to 60 calendar days from the initial payment due date.

If the payment is not made by the extended payment due date, the registration fails the completeness check and will be rejected.

For updates of a registration unrelated to tonnage band changes, the registrant has the possibility to request a further extension of the second deadline for payment of the corresponding fee before its expiry. In practice, this request for extension of the second deadline for payment applies only to:

  • Fees levied for new chargeable confidentiality claims included in spontaneous updates;
  • Fees levied as a consequence of a legal entity change.

The request for extension should be submitted before the expiry of the second deadline via the ECHA Helpdesk using the contact form on ECHA's website.

If the payment is not made by the deadline of the extension, the update fails the completeness check and will be rejected.

Fees invoiced for notification of an exemption for product and process oriented research and development (PPORD), as well as charges for requests to extend this exemption.

Fees for notification of PPORD exemptions: the initial payment due date of the fee is 7 calendar days from the date on which the invoice was notified to you. Requests to extend a PPORD exemption: the initial payment due date of the fee is set at 30 calendar days from the date on which the invoice was notified to you.

If the payment has not been made within the prescribed period (by the initial payment due date), ECHA will set a second deadline. This second deadline (extended payment due date) is usually up to 60 calendar days from the initial payment due date.

Where the payment is not made by the expiry of the second deadline, the notification or the request for an extension will be rejected.

How do I pay ECHA's invoice?

Bank transfer is the only accepted payment method. Other types of payment, such as cheque, banker's draft or cash, are not accepted by ECHA.

Payments should be executed in Euros only and it must be ensured that the full amount of the invoice is received by ECHA. Deductions of bank charges, from exchange rate differences or of any other costs will lead to an underpayment of the invoice.

The following bank details are indicated on all invoices issued under the REACH Regulation:

 
Bank: Pohjola Bank Plc, P.O. Box 308, FIN-00013 POHJOLA Finland
Account number: 500001-20243349
IBAN Code: FI9850000120243349
BIC/SWIFT Code: OKOYFIHH
 

Please note that separate instructions for the payment of Appeal Fees exist. These are explained in the relevant section of the Board of Appeal on ECHA's webpage.

In the payment instruction, the invoice number should be indicated as the reference number. According to Article 17(1) of the REACH Fee Regulation (EU) No340/2008, in its latest version (see QA 716), every payment must indicate the invoice number. Thus, in the free text message/communications field of the payment you should indicate only the payment reference indicated on the invoice. It is comprised of eight digits and you will find it next to ECHA's bank details on the invoice. This is very important, as your payment is automatically processed by REACH-IT. Please instruct your accounts payable/payments department and your bank accordingly.

What are the consequences of not paying an invoice within the extended payment due date?

Where the payment of a fee is not made by the extended payment due date or by the extension of the second deadline, the submission will be rejected or deemed not to be received. In the above mentioned cases, a rejection due to non-payment is not related to the status of the technical completeness check (TCC). Your submission will be rejected regardless of a given prolonged deadline to fulfil information requirements by submitting further information. Furthermore, if your submission is rejected, the REACH Fee Regulation (EU) No340/2008, in its latest version (see QA 716), stipulates that the fees paid in relation to that submission before its rejection shall not be refunded or otherwise credited to you. After you have received the rejection letter, you are able to start your submission process from the beginning.

Why is ECHA's invoice without value added tax (VAT)?

ECHA does not carry out an economic activity within the meaning of Directive 2006/112/EC on the common system of value added tax. This means that no VAT has to be paid on the fees defined in Regulation (EC) No 340/2008 ('the REACH Fee Regulation'). For the reason above, ECHA has no VAT number and ECHA's invoices are exempt from VAT. ECHA's Finnish Business ID number is 2139942-8 and it is always mentioned on ECHA's invoices. However, this number is not a VAT number.

Why are the activities of ECHA not taxable?
It is important to note that ECHA is not a private company or a service provider but a European public authority established by Regulation (EC) No 1907/2006 ('the REACH Regulation') which is directly applicable in all Member States. Article 102 of REACH provides that the Protocol of Privileges and Immunities of the European Communities shall apply to the Agency. This Protocol is part of the EU Treaties also directly applicable in all Member States, and according to the Protocol, the Agency is exempt from all taxes.
 
The exclusion of ECHA activities and transactions from taxation also results from Article 13(1) of Directive 2006/112/EC (2 on a common system of value added tax, which stipulates:
 
"States, regional and local government authorities and other bodies governed by public law shall not be regarded as taxable persons in respect of the activities or transactions in which they engage as public authorities, even where they collect dues, fees, contributions or payments in connection with those activities or transactions".
 
As it is not a taxable person, ECHA does not have a tax residence in any Member State and thus has no taxation number in Finland.
 
The invoices that ECHA sends to companies relate to fees for PPORD notification, registration and other submissions that ECHA collects pursuant to Regulation (EC) No 1907/2006 ('the REACH Regulation') and Commission Regulation (EC) No 340/2008 ("the REACH Fee Regulation"). Thus, they do not concern private transactions but are fees under public law applicable in all Member States. Based on Directive 2006/112/EC and particularly Article 13(1), these fees are not subject to taxation in any Member State. In the absence of taxation of the fees in any Member State or elsewhere, ECHA shall not be bound to complete any formalities imposed on taxable persons for the avoidance of double taxation.
 

Thus it is important to note that ECHA is unable to provide registrants a VAT or a withholding tax / tax at source residence certificate. As ECHA has no tax residence in any Member State. In QA 739 ECHA has published a financial identification form confirming its Finnish business ID.

1) OJ C 310, 16.12.2004, p. 261
2) OJ L 347, 11.12.2006, p. 1
How long does it take until ECHA receives my payment?

Since 1 November 2009, a SEPA payment must be transmitted within three banking business days. The bank statement of any given day is available to ECHA only on the next banking business day. Therefore, it normally takes up to five banking business days before ECHA can handle your payment and confirm the invoice as paid in REACH-IT. Please note that the handling time may be longer if your payment cannot be dealt with automatically. By following ECHA's instructions regarding payments you can significantly reduce ECHA's handling time of your payments (see QA 721).

How does ECHA handle my payment?

On the basis of the daily electronic bank statement, REACH-IT automatically matches your payment with your open invoice if you have indicated the correct payment reference (invoice) number in your payment message and you have paid the correct amount. An additional condition is that you pay each invoice separately as a single payment. One bank transaction per invoice therefore ensures the fast registration of your payment.

ECHA strongly advises you not to pay two or more invoices in the same transaction ("multiple invoice payment"). If you however include more than one invoice in the payment, please make sure that the invoice references are mentioned in full. Otherwise, the payment has to be manually handled by ECHA's accounting department. This may delay the processing of the payment and thus also the overall completeness check of your registration. If, for some reason, you cannot avoid sending multiple invoice payments and you are unable to indicate the full reference numbers in the payment, please make sure to follow the instructions in QA 732, which describes the sending of payment advices.

How can I help ECHA to swiftly deal with my payment ensuring a successful registration?
Your payment can be swiftly dealt with by ECHA if the guidelines below are followed when making your bank transfer:
  1. Pay one invoice per transaction (single payment);
  2. Indicate the correct reference number (eight digit invoice number);
  3. Ensure the invoiced amount is paid in full (no charges or exchange rate differences);
  4. Instruct your bank to send a SEPA payment with shared cost.
If you discover a mistake after your payment has been made, please immediately contact ECHA via the ECHA Helpdesk web form available at http://echa.europa.eu/contact.
 
How should I react to an invoice reminder?
ECHA sends you one invoice reminder for an unpaid invoice. The reminder contains an extended due date. The invoice reminder is automatically sent by the REACH-IT system one day after the initial due date. (see QA719).
If you receive a reminder but you have already paid the invoice, you can ignore the reminder.
If you have not yet paid when you receive the reminder, please make sure that you respect the extended due date as your REACH submission will otherwise be rejected.
Please note that there are separate instructions for appeal fees.
 
How can I see that ECHA has received and validated my payment?

ECHA does not send confirmations of receipt of payment, but you can check the status of your invoice in REACH-IT in the submission report section. The "Pay Submission Fee" has the status "Succeeded" when your payment has been validated. Please note that it may take several days before ECHA receives the payment depending on the payment method.

A SEPA payment is transmitted within three bank business days. A submission is subject to both a technical and a financial completeness check. Therefore, a fully paid invoice does not necessarily indicate an accepted submission of your REACH dossier.

When should I provide ECHA with a payment advice?
A payment advice can either be an extract from your accounts payable department attached to your email message in PDF format or simply a list of the invoice numbers paid, their total amount and the payment date in the email message itself.
 
A payment advice must be sent in the following cases:
- your payment reference (invoice) number was incorrect;
- in the case of a multiple invoice payment where each invoice number is not mentioned in the bank payment message;
- by request of ECHA's accounting department.
 
If you have indicated the reference (invoice) number in your payment message and it is correct, ECHA does not need any separate payment advice.
 
A payment advice should be sent to the email address of ECHA's accounting department which is: payments@echa.europa.eu.
Please indicate 'Payment advice and the payment date' in the subject field. Example: "Payment advice 19 March 2016".
 
No payment advice by conventional mail is required unless ECHA exceptionally requests it.
What is a proof of payment and when does it need to be sent to ECHA?
The proof of payment can either be a copy of your bank statement or a separate confirmation stamped by your bank.
 
The bank statement can serve as proof that you paid ECHA's invoice by the extended due date. The bank statement copy or the document stamped by your bank must clearly show the date when you ordered the bank transfer.
 
If ECHA has received your proof of payment but has not received the payment within a time period judged normal for bank transfers, ECHA's accounting department will contact you.
 
Please observe that a payment advice printed from your accounting programme is not a valid proof of payment. A proof of payment needs to be issued or officially certified by your bank.
 
Proofs of payment should be sent as scanned PDF attachments to the email address of ECHA's accounting department: payments@echa.europa.eu.
 
No proofs of payment by conventional mail are required unless ECHA exceptionally requests them.
 
Does ECHA send credit notes?

If an invoice is cancelled (e.g. incorrect information on the invoice, such as billing information, company size and etc.), you will receive a credit note for the whole amount and, if needed, a replacement invoice. These electronic documents can be downloaded from your REACH-IT account in PDF format.If you receive two invoices and one credit note, the reference number you should indicate in your bank transfer is the reference number of the latest invoice.

If you pay an invoice for which ECHA later issues a credit note, the paid amount will be credited back to your company by either reallocating the received amount to another unpaid invoice or refunding the amount to you.

Please be informed that ECHA doesn't provide any credit notes in case the invoice was not paid in full and your registration was rejected.

What are the rules for a refund?
In certain cases of double payment or overpayment, ECHA will refund the received amount paid in excess. Moreover, fees or charges paid after the rejection of the submission are refunded as undue payments.
 
For the payment of refunds, ECHA will request the bank account information of your company. In addition, ECHA requires your company to complete and sign the following two forms in order to process the refund:
 
"Legal entities" which can be found at:
and "Financial identification" that can be found at:
 
You can choose your preferred language. Please also read the privacy statement.
 
However, please note that fees or charges paid in relation to a submission before its rejection cannot be reimbursed or otherwise credited pursuant to Articles 3(7), 4(7), 5(7), 7(5), of the Fee Regulation and Article 20(2) of the REACH Regulation (Regulation (EC) No 1907/2006).
 
For more details on the rules and procedure, please refer to ECHA Decision ED/61/2008 on refund of fees and charges pursuant to Article 10(4) and 20(1) of the Commission Implementing Regulation (EU) No 254/2013 of 20 March 2013 amending Regulation (EC) No 340/2008. The Decision on refund of fees and charges is available at: http://echa.europa.eu/documents/10162/13559/ed_61_refund_fees_charges_en.pdf
Do ECHA invoices have to be electronically signed?
After your submission has been received by ECHA, you will receive your invoice electronically via REACH-IT – no paper invoice is sent. Invoices can be downloaded in PDF format from your REACH-IT account.
 
The requirements mentioned in Directive 1999/93/EC on electronic signatures do not apply to invoices issued by ECHA. The rule on electronic signature of invoices is based on Article 233 of Directive 2006/112/EC ('the VAT Directive'), which according to Article 220, only applies to taxable persons. However, ECHA is not a taxable person, but an EU public body that does not carry out any economic activity.
 
In any case, the purpose of the provisions of the VAT Directive relating to electronic invoices is to guarantee the authenticity of the origin and the integrity of the content. For invoices notified by ECHA, this objective is met in a more efficient way. Invoices issued by ECHA are notified to their recipient through REACH-IT, which is a secured online platform through which only ECHA can notify information to individual registrants in confidence.
How can I prepare my accounts payable department or my accounting company in view of ECHA's invoices?
In order to ensure the timely payment of ECHA's invoices we recommend the following:
 
All the information you need for proceeding with the payment is visible in the invoice itself. However, depending on your internal administrative procedures, it is advisable that your accounting/accounts payable department is prepared for the payment of ECHA's invoices.
 
We therefore recommend that you set up ECHA's bank account information in the accounting system well in advance of the first invoice's due date. The following link contains ECHA's financial identification form with all the needed details: http://echa.europa.eu/documents/10162/13611/echa_financial_identification_sheet_en.pdf
 
If you use an external accounting company, please ensure that all required information about ECHA and REACH is passed on, in order to ensure the smooth handling of ECHA's invoices. It is also advisable that you ensure beforehand that there are no misunderstandings related to ECHA's status as an EU body which is exempt from any national tax or any value added tax. Please refer to QA 725 and 726.
 
Please make sure that the persons handling the payments of ECHA's invoices are aware that the payment should be made at the full amount so that any possible bank charges are not deducted from the payment.
 
Please inform your accounting department that if the invoice is paid after the extended due date, the REACH dossier submission will be rejected and the paid fee will not be refunded.
 

Please ensure that ECHA’s invoice number is stated in the payment instruction (see QA 721).

What information about my company appears on ECHA's invoice and credit note?
The following information about your company will be visible on the invoices, invoice reminders and credit notes:
 
  • Company name and billing address indicated by the registrant (the information filled in the tab "Billing company information" in REACH-IT is the one that will appear on the invoice);
  • Customer ID number (= Legal entity UUID);
  • DUNS number and VAT number (if provided by the registrant during the sign-up, can be modified later on in the company information section);
  • Purchase order number (if provided by the registrant when submitting the dossier or when accepting a legal entity change).
Before submitting the dossier, please make sure that all the above mentioned information is correctly indicated in your REACH-IT account if you require it to be visible on ECHA's invoice.
Does ECHA need a purchase order for my submission?
When submitting a dossier or accepting a legal entity change, you are able to indicate your own internal purchase order number. It is not possible to add any forgotten purchase order number or modify it afterwards.
 
As you register online in REACH-IT you should not send any purchase orders by ordinary mail or email to ECHA. Please make sure that your system does not send any purchase orders automatically to ECHA. Your purchase order is only for your internal purposes. ECHA will not confirm your internal purchase order or provide information to or access third party platforms for handling your purchase orders.
 
What is the contact address of ECHA's accounting department (accounts receivable)?

For any enquiry, please contact ECHA by using the ECHA Helpdesk web form that is available at http://echa.europa.eu/contact.

My company information has changed and the invoice is not correct; does ECHA issue updated invoices?

If your invoice has not been paid, ECHA will be able to cancel it and create a new one with your up-dated company information. If the invoice has been accepted and paid, ECHA is not in a position to modify the invoice.

ECHA is unable to update any company information in REACH-IT. It is the responsibility of the REACH-IT account owner within the company to make sure that the information is up-to-date.

Firstly, please update your company information in REACH-IT as soon as possible. You can easily update your information by signing into REACH-IT -> Menu -> Manage Company -> Company information here you can modify and update your information by clicking on "Update" at the top right corner of the page. Always remember to save your changes.

Immediately after the company details have been updated, you need to contact the ECHA Helpdesk by using the web form available on the ECHA website.

Company size information

Additional information on how to update your company information can be found in the ECHA Accounts manual at: https://echa.europa.eu/documents/10162/21721613/echa_accounts_en.pdf

If the changes in your company are due to a change in the company size or due to its incorrectness please refer to the SMEs section on the ECHA website.

Who is entitled to a fee waiver?

You are entitled to the fee waiver if:

  1. Your substance is a phase-in substance and considered to be low risk (i.e. does not meet the Annex III criteria of REACH); and
  2. You submit a standard registration dossier for 1-10 tonnes per year voluntarily providing the full set of information listed in Annex VII.

The fee waiver does not apply if:

  • Your substance is considered to be low risk (i.e. does not meet the Annex III criteria) and you submit a registration dossier for 1-10 tonnes per year with only physicochemical information (listed in section 7 of Annex VII); or
  • Your substance is not considered to be low risk (i.e. meets the Annex III criteria) and therefore, you must provide the full Annex VII information; or
  • Your substance is a non-phase-in substance.
The above is based on Articles 12(1)(a) and 74 of REACH, taking into account Recital 34 of the regulation.

Important notes
In a joint submission, the tonnage band of the other member registrants does not influence the applicability of the fee waiver for your own dossier.

You need to actively claim the fee waiver in IUCLID to benefit from it – the system does not grant it automatically.

More information on the Annex III criteria and their applicability can be found here.

 

Joint submissions

General questions

How can I confirm my membership to a Joint Submission in REACH-IT before I submit my member registration dossier?

The lead registrant of a joint submission will provide you with a combination of joint submission name and security token outside of the REACH-IT environment (e.g. by email, phone). To confirm your membership, log in to REACH-IT and use the ‘Join existing Joint Submission’ functionality and follow the wizard.
joint submission

Member registrants will also need to indicate their membership to a joint submission by adding the joint submission name during the submission of their registration dossier in REACH-IT. The information provided in section 1.5 of the IUCLID 6 registration dossier can be used for your own administrative purposes, but this information will not be verified against the information derived from REACH-IT.

Member registrants cannot submit their dossiers until the lead dossier has been accepted for processing by ECHA. The status of the lead dossier can be checked in the joint submission in REACH-IT.

How can I delete a joint submission (JS) in REACH-IT?

To delete a joint submission search for your joint submission in REACH-IT and use the ‘Delete joint submission’ functionality.
delete joint sibmission

The JS can only be deleted if:

  • There are no members in the JS (active or inactive)
  • There are no submissions linked to the JS (failed or passed)
How can I transfer the lead registrant role in REACH-IT to another member of the joint submission?

If the current lead registrant does not want to continue in their role as lead, it is up to the SIEF members to choose a new member, who will take over the lead role. In order to transfer the role, the following shall be observed:

  • The current and the future lead registrant need to agree on the handover. Then, the following actions must be performed within the Joint Submission in REACH-IT:
    • The current lead registrant will need to assign the lead role to the future lead registrant using the ‘Assign New Lead’ button. The future lead registrant, should already be a member of the joint submission.
    • Then, the future lead registrant should accept the assignment by clicking ‘Confirm Lead’ button and subsequently become the lead registrant in the Joint Submission.
  • The new lead registrant needs to submit a lead dossier containing all the information to be provided on behalf of the joint submission. If the new lead registrant has previously submitted a registration dossier for this substance, the lead dossier should be submitted as a spontaneous update.
The initial lead registrant is still legally considered as the lead registrant of the joint submission until all above mentioned steps are carried out.

 

How can I create a joint submission by selecting manually the substance identity?

The joint submission is created by the lead registrant using the pre-registration number, inquiry number or the registration number.

When none of these identifiers are available, or the pre-registration number refers to a submission that does not correctly define the substance identity, you should proceed as follows: Select Menu >> joint submission >> Create new.

Read carefully the information provided on the right side of the page. If you are certain that you do not have any reference number, click on the link ‘substance identity manually’ and follow the wizard.
create submission

How do I change from an individual to a joint submission?

An individual registrant who wants to become part of a joint submission needs to submit a spontaneous update and indicate that their registration is part of a joint submission. Before submitting, they have to confirm membership of the joint submission, in this case the lead registrant needs to provide the joint submission name and the security token.

Once you have the information required, you can confirm membership by signing in to REACH-IT >> Select Menu >> Joint Submission >> Join existing and enter the joint submission name and security token and follow the wizard.

When updating the dossier in IUCLID pay attention to the following:

  • Enter the registration number in section 1.3 of your substance dataset
  • Create the registration dossier by right-clicking the substance and selecting "create dossier" and follow the wizard
  • Choose the template "REACH Registration member of a joint submission –general case/ - intermediate" depending on your submission.
  • Indicate the reason for update as "Change from individual to joint submission"
Can I update my individual dossier without creating/joining a joint submission, even though multiple registrants exist?

As long as your registration fulfils the criteria listed below, you are allowed to update it, even if there are other individual registrations in the system:

  • There are only individual registrants and no joint submission exists in REACH-IT.
  • You are not changing your registration type with your update. For intermediate registrations, changing your registration to mixed or full is only possible if there is no other mixed/full registrant (either as part of a joint submission or as individual registrant).

Any potential or existing registrant can create and submit a joint registration. This joint registration will block all the individual registrants of the same substance and same registration type from being able to update their dossiers, until they join the joint submission.
 

Can I update my joint registration even though another joint submission for the same substance exists?

We highly encourage you to start negotiating with the other joint submission on merging into one, as in the future it will be unavoidable.

However, for the time being, you are still allowed to update your dossier without any limitations, as long as you are not changing the type of your registration. For intermediate joint submissions, changing your registration to mixed or full is only possible, if there is no full joint submission already created for the substance, or there are no full registrations outside of a joint submission.
 

How can I find other joint submissions in REACH-IT?

Once a potential member of the joint submission has pre-registered, registered or inquired about a substance, they will always be able to find the Joint Submission and the Lead Registrant’s details by using the Joint Submission functionality and by ticking the option ‘Show other joint submissions’, regardless of whether the Lead Registrant accepted to have their contact information published. (see example screen shot below).

Joint submission

If a potential member of the joint submission has not pre-registered, registered or inquired about a substance and the Lead registrant accepts to publish their contact information, they will still be able to find the Joint Submission and the Lead Registrant’s details by using the Joint Submission functionality and by ticking the option ‘Show other joint submissions’.

If a potential member of the joint submission has not pre-registered, registered or inquired about a substance and the Lead registrant does not accept to publish their contact information, they will not be able to find the Joint Submission and the Lead Registrant’s details. In this case, the potential registrant should try to find the contact details of the Lead registrant and the Joint Submission through the contacts of other potential registrant in pre-SIEF.

List of lead registrants

Why is my substance not listed in the lead registrants’ substance list?

The list published on 28 Sep 2016 contains information only of the substances that were preregistered by end of 2008. This limitation of the first publication was done in order to secure that no confidential information is published, and that ECHA has enough time to make the broader version ready later this year (see below).

In October-November 2016, ECHA will update the list to include information of all substances that are published at the ECHA Dissemination website, covering then also late preregistered substances and even new substances where the lead has accepted the publication of the company name information and the substance identity information has not been claimed confidential in existing registrations. This will increase the number of substances by 1300 and at that time, more substances will be visible, including most likely also your missing one.

Link to 2008 preregistered substances: https://echa.europa.eu/information-on-chemicals/pre-registered-substances.
Link to all registered substances: https://echa.europa.eu/information-on-chemicals/registered-substances.

It might be that the lead has not formed the Joint Submission object in the REACH-IT yet. If you know the lead, and you already are a member in the same pre-SIEF or SIEF, check the status directly from your lead.

A substance is missing from the list because your pre-registered substance does not yet have a declared lead registrant. You can consider becoming the lead and announcing it to your co-registrants on the pre-SIEF page in REACH-IT. To become a lead registrant, you will need the agreement of your co-registrants. Help to get started is available through phase 2 of the REACH 2018 Roadmap.

How can I be sure there is no confidential material published on the List of lead registrants

ECHA removes all confidential information before compiling the list of lead registrants. Joint Submission information are not published if the substance identity has been claimed confidential in all JS registrations dossiers. The information on the List of lead registrants mirrors the information published on ECHA’s dissemination webpage.

Why are some Lead names on the List of lead registrants marked as ‘Available in REACH-IT’?

When creating a Joint Submission the lead registrant can refuse to publish their contact details.
contact details
In this case, the contact details of the lead registrant will not be publicly available on the List of lead registrants and the entry will be marked ‘Available in REACH-IT’’.

This means that only companies, that have registered, pre-registered or inquired about this substance will be able to find the contact details in REACH-IT. (See Q&A 1220).

 

I am a Downstream User and my substance is not on the List of lead registrants. Will I be able to buy the substance if none of my suppliers has a valid registration?

A supplier, who has a valid pre-registration, can manufacture/import the substance below 100 tonnes per year without a registration until the registration deadline on 31. May 2018. After this day the supplier will only be able to manufacture/import your substance above 1 tonne per year, if they have a valid registration.

There can be a number of reasons, why your substance is not on the List of lead registrants:

  • Suppliers are still gathering data and have not formed the Joint Submission yet
  • Your supplier is an individual registrant and no Joint Submission will be created for your substance
  • The annual quantity of the substance manufactured or imported by the individual suppliers is below 1 tonne per year (so there is no 2018 registration requirement)

We advise you to contact your supplier(s) to find out what they are doing to ensure your supply.

What is the List of lead registrants?

When creating a Joint Submission the lead registrant can accept to publish their contact details.

ECHA publishes the contact details of these lead registrants on the List of lead registrants. The list includes the substance identity, registration type and creation date and whether or not the lead dossier has been submitted.

The lists is available both in pdf and excel and can be found at:

https://echa.europa.eu/regulations/reach/registration/registration-statistics.

Why is my substance not listed in the List of lead registrants?substance list?

There may be several reasons, why a substance has not been included to the List of lead registrants:

  • The substance is still in the pre-SIEF stage and no lead registrant has been appointed.
  • The lead registrant has been appointed, but has not formed the Joint Submission object in REACH-IT.
  • There is a joint submission, but all members have claimed their substance identity confidential.
  • Your supplier is an individual registrant and no Joint Submission will be created for your substance
  • The annual quantity of the substance manufactured or imported by the individual suppliers is below 1 tonne per year (so there is no 2018 registration requirement)
One substance, one registration

My submission failed business rules verification, stating that I should submit my registration jointly. What does this mean?

Following the entry into force of the ‘Commission Implementing Regulation (EU) 2016/9 on Joint Submission of Data and Data Sharing', new checks were put in place to ensure that all submissions are in line with the ‘one substance, one registration' (OSOR) principle. According to the OSOR principle there can only be one joint registration per substance per registration type (full or intermediate).

Furthermore, if an active joint submission already exists (i.e. the lead registrant has successfully submitted the lead dossier), individual registrants (i.e. not part of the joint submission) for the same registration type (full or intermediate) are blocked from updating their dossiers, unless they become members of the joint submission.

ECHA advises you to take the following steps:

  • Find your co-registrants.
  • Establish substance sameness and negotiate on data sharing.
  • For the scenarios described in QA 1171, you can partially or fully opt-out from information submitted jointly by your co-registrants. However, your submission still has to be in the framework of the joint submission. Therefore, certain administrative fees may be applicable towards the joint submission.
  • If you cannot agree on the data and cost sharing, you can file a data-sharing dispute with ECHA. The dispute mechanism should be used as a last resort and you will need to demonstrate that you have made every effort to reach a voluntary agreement.
  • If you wish to submit a partial or full opt-out, but cannot come to a voluntary agreement with the lead registrant on the conditions for joining the joint submission, you can also use the above-mentioned dispute mechanism.

 

What are the constraints for updating my registration dossier under the ‘one substance, one registration' (OSOR) rules?

If you are an individual registrant and no other company has registered the same substance, you will not face any constraints when updating your registration.

If there are other registrants for the same substance, you will have to fulfil certain criteria to be able to update. Below you can find the scenarios of your case:

  • A joint submission exists for the same substance and same registration type and your registration is outside of this: You cannot update your dossier, until you join the joint submission.
  • A joint submission exists for the same substance and same registration type and your registration is part of it: You can update your registration without any limitation, as long as you are not changing the type of your registration. For intermediate joint submissions, changing your registration to mixed or full is only possible if there is no full joint submission already created for the substance, or there are no full registrations outside of a joint submission.
  • No joint submissions exist for the same substance and for the same registration type (full or intermediate), but other individual registrations have been submitted: You can update your registration without any limitation, as long as you are not changing the type of your registration or until a joint submission is created. For intermediate registrations, changing your registration to mixed or full is only possible if there is no full joint submission already created for the substance, or there are no full registrations outside of a joint submission.
Under what circumstances can a registrant submit partially or fully separate data from other members of the joint submission?

Registrants must always submit their information within the framework of a joint submission. However, registrants can submit some information separately, if: 

  • it would be disproportionately costly for them to submit some information jointly, or
  • submitting the information jointly would lead to the disclosure of commercially sensitive information that would likely cause substantial commercial detriment, or
  • they disagree with the lead registrant on the selection of information.

Registrants who fall under any of the above circumstances can submit some or all data on their own: these are respectively called partial and full opt-out. Technical implementation of the opt-out is described in Q&A 396.

 

 

 

I submitted an individual registration and ECHA has requested that I update my dossier. Can I make the update without creating/joining a joint submission?
  • If there is a joint submission for the same substance you will need join the joint submission in order to submit the update.
  • If there is no joint submission, but there are individual registrants for the same substance, you should create a joint submission and take up the role as lead registrant before submitting the update.
  • If there is no joint submission and you are the only individual registrant, you can update your registration without creating the joint submission.
  • None of the above applies, if the update requested is linked to a technical completeness check (TCC) failure. In this case you submit an update as individual member.
Submitting an opt out dossier

I could not come to an agreement with the lead registrant on information requirements. How can I opt out of a Joint Submission?

Registrants may submit information covered in Article 10(a)(iv), (vi), (vii) and (ix) of REACH separately if:

  • it is disproportionately costly to submit this information jointly; or
  • it would lead to the disclosure of information which he considers to be commercially sensitive and may cause substantial detriment; or
  • there is disagreement on the selection of this information.

In such cases, you can partially or fully opt-out of the joint submission and include all endpoints you want to opt out of to your member dossier. An opt-out (partial or full) does not allow submitting a registration dossier outside the framework of the joint submission. Even if you fully opt-out, you may still be requested to participate in the cost sharing of the relevant administrative fees associated with the management of the joint submission.

In case of an opt-out, you are required to:

  • remain part of the joint submission
  • submit your own information to cover the data requirement
  • submit a clear and reasoned justification for opting out
  • include opt-out information in section 14 of IUCLID 6 dossier

REACH registration dossier of a member registrant

  • Sections 2, 4, 5, 6, 7 and 8 of the member dossier should be left empty if the member registrant relies on the information provided in the lead dossier.
  • If a member registrant submits a dossier with any of these sections filled in, the submission is regarded as an opt-out (see picture below).

opt out

How can I increase the Joint Submission’s tonnage band?

To increase the Joint Submission tonnage band, the Lead Registrant needs to submit a spontaneous update. Please note, that the increase of tonnage band of the Joint Submission may require additional data to be provided in the Lead Dossier.

In Dossier Creation Wizard

Step 1

The tonnage band indicated in submission type (IUCLID 6 template) represents the tonnage band of the Joint Submission. Please pick the same submission type as was used from the last successful submission at a higher tonnage band.
step 1


step 2

 

Step 2

The administrative information of the dossier represents the data of the Lead Registrant. The tonnage band indicated in this step represents the tonnage band of the Lead Registrant’s own registration.

Keep in mind that the lead registrant can have his tonnage band different from the tonnage band of the Joint Submission, while the information required for the lead dossier is based on the highest tonnage band of any Joint Submission member. If the Lead Registrant increases his own registration’s tonnage band, a new invoice will be triggered.

Mark the dossier as an update, add the last successful submission number and chose ‘change of tonnage band’ from the drop-down menu as justification for the spontaneous update.

How can I decrease the Joint Submission’s tonnage band?

Step 1

Before decreasing the Joint Submission tonnage band, the Lead Registrant needs to make sure that all members of the Joint Submission, except for the Lead himself, have the tonnage band equal or below the decreased (new) JS’s tonnage band. Members can update their own tonnage band by submitting a spontaneous update.

The tonnage band of Intermediate registrations do not affect the tonnage band of the full joint submission, therefore, a member with an intermediate registration can have a higher tonnage band than the decreased Joint Submission.

Step 2

The Lead Registrant has to contact ECHA via the contact form and request that ECHA performs the decrease of the Joint Submission tonnage band.

If a consultant is representing the Lead Registrant, a signed request by the Lead Registrant needs to be submitted.

Step 3

After ECHA has decreased the Joint Submission tonnage band, the Lead Registrant has to submit a spontaneous update using the same submission type (IUCLID template) that was used for the last successful submission, but at a decreased tonnage band.

In the same update, the Lead Registrant has to update its own registration’s tonnage band (administrative information) to be equal or lower than the decreased tonnage band.

step 3

Mark the dossier as an update, add the last successful submission number and chose ‘change of tonnage band’ from the drop-down menu as justification for the spontaneous update.

step 3

In the same update, the Lead Registrant has to update its own registration’s tonnage band (administrative information) to be equal or lower than the decreased tonnage band.

Nota bene: If a final decision from ECHA was sent to the Joint Submission members, they will need to comply with such decision even after the tonnage band decrease.

 

Can the tonnage band of the lead registrant be below the Joint Submission tonnage band?

Yes. If the lead registrant want to lower his tonnage band below the tonnage band of the Joint Submission, the Lead needs to submit a spontaneous update.

In Dossier Creation Wizard

Step 1.

The tonnage band indicated in submission type (IUCLID template) represents the tonnage band of the Joint Submission and should remain the same as used during the last successful submission.

Step 2.

The administrative information of the dossier represents the data of the Lead Registrant. The tonnage band indicated in this step represents the tonnage band of the Lead Registrant’s own registration, which can be equal or lower than the tonnage band of the Joint Submission, indicated in submission type.

How do I change the registration type of my Joint Submission?

If there is full agreement among the members of a Joint Submission and there is no Joint Submission of the different type, a formal request signed by all members can be sent to ECHA in order to change the registration type from Intermediate to Full or from Full to Intermediate.

All Members will need to submit a spontaneous update and change their submission type.

Legal entity

A. General

What documentary evidence is considered adequate if a legal entity change involving a total "sale of assets" occurs? Does ECHA verify the adequacy of the submitted documentation?

The final decision on what documentation is considered adequate evidence of a ‘sale of assets’ is determined on a ‘case by case' basis in accordance with the relevant national principles of private and corporate law of the Member State where the entity is established. For this reason ECHA Practical Guide 8 – How to report changes in identity of legal entities limits itself to the general example of the asset sales agreement and does not provide further information in this regard.

The relevant documents should be presented to the national enforcement authorities upon request. Ultimately, the REACH duty holders bear responsibility for the submission of adequate documentary evidence. To ensure that it complies with the national legal order they may seek legal advice from in-house or private practice lawyers, for example.

More information on changes in identity of legal entities can be found in the aforementioned Practical Guide 8 – available at http://echa.europa.eu/practical-guides.

 

 

Do I need to take into account any linked or partner non-EEA companies, when determining the SME status?

Yes, according to Article 12 of the Fee Regulation (EC) No 340/2008 and the references therein to the definitions concerning micro, small and medium-sized enterprises as set out in the Annex to the European Commission Recommendation 2003/361/EC, both EEA and non-EEA companies are to be considered for the classification of partner and linked enterprises during the determination of the SME status of a company. Moreover, the non-EEA company is the very entity under consideration, in case when a submission is made by an Only Representative, as specified in Article 12 of the Fee Regulation.

How can I update and synchronise my legal entity (LEO) information?

There is no need to synchronise the company details in REACH-IT and IUCLID. The legal entity information is always extracted from the information in REACH-IT.

However, if you wish to do so, we recommend updating the information in REACH-IT, and later exporting it to your IUCLID 6. If you update your LEO information in your IUCLID 6 application, remember also to update your LEO information in REACH-IT.

Step by step instructions on how to update and synchronise the LEO information can be found in chapter 2.1 of ‘How to prepare registration and PPORD dossiers’ manual at: http://echa.europa.eu/manuals.

 

 

What is the outcome of a legal entity change?

The legal successor should observe the following when a legal entity change is validated in REACH-IT:

Transferred items (i.e. registrations/notifications)

You must not transfer an item that is already available in the legal successor's account for the same substance. E.g. If a registration for a substance is transferred from the legal initiator to the legal successor, who already has a valid registration for the same substance, the transferred registration will overwrite the pre-existing registration in the account of the legal successor. The status of the pre-existing registration will be marked ‘Annulled’, because a legal entity can only have one registration for the same substance.

Tonnage band update

For transferred registrations when the originating legal entity has registered the same substance as the legal successor and the tonnage of the originating legal entity is higher than the registered substance of the legal successor, the system will keep track of the legal successor's right to a higher tonnage band. The legal successor will still need to submit a spontaneous update to indicate the higher tonnage band. For transferred pre-registrations, the tonnage band will not be updated when a legal entity change is completed for the same pre-registered substance. In this case, the legal successor will have to modify the pre-registration as explained in Q&A 345.

Joint Submission

Where the originating legal entity transfers a registration which is part of a joint submission, the original legal entity's role in that joint submission is transferred to its legal successor. Both lead and member registrant roles are transferred. However, if the originating legal entity transfers a pre-registration where its membership to a joint submission has been confirmed, this joint submission membership will not be transferred to the legal successor.

Pre-SIEF

When a legal successor enters the pre-SIEF contact details during the validation of a legal entity change, these details will be updated in the pre-SIEF of all the pre-registrations of that legal successor. The pre-SIEF contact details will however need to be updated if you wish to add additional contact persons in the transferred pre-registrations once the transfer is complete. Pre-SIEF contact details will not be updated if you already have a successful registration for a pre-registration with the same substance identification.

Invoicing

The Agency will issue an invoice for the legal entity change pursuant to Commission Regulation (EC) No 340/2008 Article 5 (Fee regulation) if the item list contains one or more payable items.

  • Items that trigger a fee during a legal entity change are: Registrations, Registration of on-site isolated intermediate, Registration of transported isolated intermediate.
  • Items that trigger do not trigger a fee during a legal entity change are: Pre-registrations, Product and Process Oriented Research and Development (PPORD) notifications, Classification and Labelling (C&L) notifications, Inquiry notifications.

Where an invoice is needed (i.e. the legal entity change includes at least one payable item), only one invoice will be issued per legal entity change.

Invoices are issued to the legal successor. The company size of the legal successor after the change of legal personality will determine the fee. Pursuant to Commission Regulation (EC) No 340/2008 Annex III Table 3, a reduced fee will be invoiced to SMEs.

Only once the invoice is paid in full, will the transfer of items take place and the legal entity change be completed in REACH-IT. If the invoice is not paid within the extended due date the legal entity change is deleted from the system and items will not be transferred.

Information about the fee regulation can be found at http://echa.europa.eu/regulations/reach/legislation.

How can I download the dossier that I acquired via a legal entity change?

If you acquired a registration as part of a legal entity change, you are considered the legitimate owner of that registration.

However, a registration dossier can be requested in REACH-IT only by the legal entity that physically submitted the dossier (i.e. submitting legal entity). If you need access to the data in the registration dossier, you will need to agree with the original submitter of the dossier to provide it to you or that they can request it from ECHA.

request IUCLID file

The submitting legal entity should consider the following:

  • It is good practice that the submitting legal entity stores the registration dossier in .i6z format on their local computer. If the IUCLID dossier is lost, the submitting legal entity can request the IUCLID file from ECHA via REACH-IT.
  • It is not possible to download the original NONS registration under Directive 67/548/EEC that was successfully claimed in REACH-IT. The owner of the NONS registration needs to contact the appropriate Member State competent authority to receive their dossier files in IUCLID format.

The list of MSCA contact details is available at http://echa.europa.eu/support/dossier-submission-tools/reach-it/nons. Only if a NONS registration update has been submitted to ECHA, will the original NONS owner be able to request the IUCLID file from REACH-IT.

How do I update my company size in REACH-IT?

The company size can be updated in REACH-IT via the ‘Company size’ functionality from the main menu and selecting the ‘Update company size’ functionality. 

update company size

This will open a wizard that will guide you through the process of updating the company size. Read carefully the instructions and have the documentary evidence at hand to substantiate the companies involved in the ownership structure.

Note: This information will be considered by ECHA in future submissions to make an assessment on your eligibility for SME reductions for submissions subject to a fee and eligible for a reduced fee based on your condition as SME. ECHA strongly recommends that you keep your information on company size duly updated in your REACH-IT account.

B. SME Verification

What documents are needed in REACH-IT for SME fee reductions under REACH?

Under REACH, registrants and applicants can benefit from reduced fees established for SMEs. ECHA has the responsibility to check the size of companies who claim to be eligible for reduced fees.

Before declaring SME status in REACH-IT, companies should be familiar with the rules set by Commission Recommendation 2003/361/EC on SME definition.

To support the claim for reduced fees, companies should upload documentary proof for SME status in their REACH-IT accounts only for those submissions, which are related to the SME fee reductions. You will be able to add relevant documents to your REACH-IT account at a later moment, if needed.

The documentary evidence should include:

  • Information about the ownership structure (upstream, downstream) at the time of the submission.
  • The financial statements (consolidated, if available) together with accompanying notes for the two latest accounting periods before the time of the submission.
  • Official certificate/information confirming the average number of employees for each of the two latest accounting periods before the time of submission.

The above listed documents should be provided for all partner and linked enterprises, as defined by Article 3 of the Commission Recommendation 2003/361/EC.

If the company acts as an Only Representative, the assessment of whether the SME reduction applies should be done by reference to the headcount, turnover and balance sheet information of the non-EU represented company and its linked and partner enterprises.

The list of documentary evidence accepted by ECHA you can find here:

http://echa.europa.eu/support/small-and-medium-sized-enterprises-smes/sme-verification.

Instructions on how to upload documents and other useful information about new REACH-IT you can find in Discover REACH IT at: http://echa.europa.eu/documents/10162/22308542/discover_reach_it_en.pdf.

More information on company’s size assessment and links to relevant legislation you can find in ECHA’s webpage at:

http://echa.europa.eu/support/small-and-medium-sized-enterprises-smes/sme-fees-under-reach-and-clp.

 

When do the documents submitted for SME verification require a certified translation?

If the original version of any document is not in one of the official languages of the European Union, a certified translation should be provided.

Legal basis for certified translations is Article 13(3) of the amended Regulation (EC) No 340/2008 on the fees and charges payable to the European Chemicals Agency pursuant to Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). Please see it at: 

http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:079:0007:0018:EN:PDF

A certified translation is the one which is accompanied by a signed statement that the translator is competent in the source and target languages (a sworn translator) and that the translation is an exact and accurate translation of the source document. The certified translator should have a certificate or a stamp that identifies the services provider and his qualification.

How does a cessation of manufacturing or import of substances affect the SME verification process?

The SME verification process relates to your information obligations at the time of submitting your registration, which includes the obligation to inform ECHA about the eligibility for a fee reduction in accordance with Article 13(1) of Regulation (EC) No 340/2008. Ceasing to manufacture or import of substances have no consequence on that obligation.

If after registering a substance, you have decided to stop manufacturing or importing it, you should still pay the applicable registration fee in full in case ECHA found that you were not eligible for the claimed SME fee reductions. Once the registration fee is paid and, therefore, your registration can be considered complete, you can indicate in REACH-IT that you have ceased the production or import of a substance. If at a later stage you decide to restart manufacturing or importing it, you would only need to report it again in REACH-IT and the registration would still be valid. Otherwise, you would need to submit a new registration and pay a new registration fee.

In case the balance to the correct registration fee is not paid, such registration will be de-activated in ECHA’s database and the rejection of the registration will be communicated to you by a decision.

How does termination of the Only Representative (OR) contract with non-EU enterprise affect the SME verification process?

The SME verification process relates to your information obligations at the time of submitting your registration, which includes the obligation to inform ECHA about the eligibility for a fee reduction in accordance with Article 13(1) of Regulation (EC) No 340/2008. The termination of the OR agreement has no consequence on that obligation.

Since your represented company benefited from reduced SME fee at the time of registration, therefore you, as the appointed OR at that time, are still liable to demonstrate the eligibility for the SME fee reduction obtained, once ECHA initiates the verification of your represented company size. The failure to provide complete documentation would result in ECHA finding your represented enterprise as non-eligible for the claimed SME fee reductions. In such case, the OR would be liable for the difference between the fee already paid and the correct registration fee, as well as the applicable administrative charge.

Pre-registrations

What will happen if a company did not pre-register a phase-in substance?

If a company established in the European Community manufactures or imports a phase-in substance which the company did not pre-register, it will have to suspend its activities involving the substances concerned and register them without delay. All manufacturing and placing on the market of such substances, between the start of the pre-registration deadline and the date of suspension of activities, may be subject to penalties according to national law. Activities involving the substances concerned can only be restarted after the substance has been successfully registered and the registration number has been received from ECHA.

To obtain a registration number, the company has to:

  • Submit an inquiry according to Art. 26 of the REACH Regulation to ECHA to determine whether a registration, or an inquiry, was previously submitted for the same substance;
  • Share relevant physicochemical, health and environmental data and use information in order to compile a registration dossier
  • Submit a complete dossier to ECHA. Please note that the completeness includes also the payment of the fee.

If you want to know what substances have to be registered you may first consult the Guidance on Registration (Section 1.6 – What to register) http://echa.europa.eu/support/guidance-on-reach-and-clp-implementation.

More information on how to submit an inquiry and registration dossier to ECHA is to be found at: http://echa.europa.eu/qa-display/-/qadisplay/5s1R/view/topic/reach-it/

For further information related to registration dossiers you may visit the ECHA webpage at: http://echa.europa.eu/regulations/reach/registration

For information on the Commission Regulation No 340/2008 on the fees and charges payable to the European Chemicals Agency we kindly advice you to consult the European Commission website: http://ec.europa.eu/enterprise/reach/reach/fees/index_en.htm

How can I update the information in my pre-registration?

You can modify all information, except for the substance identity and the legal entity assigned to that pre-registration. You can update the following information:

  • contact information (both internal contact of the owner and possible third party representative),
  • similar substances,
  • envisaged tonnage band (if applicable following the restrictions detailed below,
  • the information field for the pre-SIEF if needed.

A pre-registration update is not allowed, when it involves a tonnage band change of a phase-in substance that a company manufactures or imports to the EEA in quantities:

  • above one tonne per year when your substance is classified as carcinogenic, mutagenic or toxic to reproduction, category 1 or 2, in accordance with Directive 67/548/EEC; or
  • above 100 tonnes per year.
How do I delete/deactivate my pre-registration?

A pre-registration cannot be deleted, but it can be deactivated in REACH-IT. To deactivate the pre-registration look for your substance in the pre-SIEF section of REACH-IT and use the ‘Deactivate’ functionality.


The Status column that describes the status of your participation in the pre-SIEF will turn to ‘Inactive’. You can reactivate you pre-registration at any time by using the ‘Activate ’ functionality. If you update your pre-registration while the status is inactive, the system will automatically reactivate your pre-registration.

The deactivation of a preregistration signals to other pre-SIEF members, that you are not interested in an active participation in the SIEF discussion. Note, however, that even as a non-active participant to the pre-SIEF you may still be asked to share data in the SIEF.

Note also, that the pre-registration and potential future registration of your substance are not affected by the deactivation from the pre-SIEF forum. You can benefit from the extended registration deadline if you have a valid preregistration, irrespective of its status (active or inactive).

The ‘Deactivate’ button is disabled if a third party representative was appointed for a particular pre-registration. In this case, the deactivation can only be performed by the third party representative and not by the potential registrant.

Can downstream users check online if their suppliers have pre-registered?

No, downstream users should make appropriate contractual arrangements with their suppliers to ensure that they comply with REACH.

What does ‘Read across To’ and ‘Read cross From’ mean in the pre-SIEF section of REACH-IT?

Read across To’ shows a list of substances that pre-registrants of the pre-SIEF have marked as similar substances.

Read across From’ shows a list of substances that pre-registrants of those substances have marked as similar to your substance.

Where can I see the list of substances that have been pre-registered?

Pursuant to Article 28(4) of the REACH Regulation, ECHA published a list of pre-registered substances on its website by 1 January 2009. The list includes all substances that were pre-registered by 1 December 2008. For each substance the following information is given:

  • Substance identification: EC number, CAS number and name of the substance
  • Substance identification of the similar substances, if applicable
  • First envisaged registration deadline

This list does not mention the names of the companies who pre-registered the substances. You are invited to check the list on our website at: http://echa.europa.eu/information-on-chemicals/pre-registered-substances

Am I in the wrong pre-SIEF?
A useful tool when looking for a more suitable SIEF is the list of pre-registered substances. This list contains all pre-registered substances, with the available identifiers such as EC number, CAS number and chemical name with synonyms. The list is available at:
 
Once you have found a more suitable or more specific identifier for your substance, you can use REACH-IT to view the pre-SIEF of this "other" substance. You will need to update your pre-registration by adding this "other" substance in the "similar substances" tab. From the pre-SIEF page of your substance, you will then be able to navigate to the pre-SIEF page of this "other" substance. As you will not be listed as a member of this pre-SIEF automatically, you will have to take the initiative and get in contact with the pre-registrants therein to explain that you wish to join the SIEF of the "other" substance.
For further information on SIEF issues we invite you to visit our SIEF section on the ECHA website: http://echa.europa.eu/regulations/reach/substance-registration/substance-information-exchange-fora.
What should I do if I am in the wrong pre-SIEF?

If you entered your substance name in a different way than the other manufacturers and importers when pre-registering, or if you realise during discussions about the sameness of your substances that you do not have the same substance as the other pre-registrants in the pre-SIEF, you may want to look for and join another SIEF.

A useful tool when looking for a more suitable SIEF is the list of pre-registered substances. This list contains all pre-registered substances, with the available identifiers such as EC number, CAS number and chemical name with synonyms. The list can be found at: https://echa.europa.eu/information-on-chemicals/pre-registered-substances

Once you have found a more suitable or more specific identifier for your substance (here bismuth tetroxide), you can use the functionality ‘Edit pre-registration’ in REACH-IT. In the second step of the wizard, you should add the other substance to ‘Similar substances’.

You are now able to navigate from the pre-SIEF page of your substance to the pre-SIEF page of the similar substance using the ‘Read across to’ tab. You will not be listed as a member of this pre-SIEF, so you have to take the initiative and get in contact with the pre-registrants to explain that you wish to join the SIEF.

How can I become the SIEF Formation Facilitator (SFF) in REACH-IT and what are the tasks?

The SFF (SIEF Formation Facilitator) is the person initiating communication with other pre-SIEF participants to start working together and ultimately submit the data in a joint submission. The SFF is visible in the pre-SIEF page in REACH-IT and is marked with the letter F for Facilitator.

To take the role of SFF, use the ‘Become facilitator’ button from the Pre-SIEF page in REACH-IT. If the button is not available, it means that someone else is already the SFF.

If you are the SFF and you no longer wish to facilitate discussions among co-registrants, you should discuss with your co-registrants if anyone is willing to take up the role of facilitator. You can delete your role as facilitator by using the ‘Stop facilitator’ button.

For further info on the tasks of the SFF, see Q&A 99.

Can I still pre-register my substance?

According to Article 28(6) of the REACH Regulation, potential registrants who for the first time manufacture or import a phase-in substance in quantities of one tonne per year or more after 1 December 2008 can submit a late pre-registration within six months of first manufacturing or importing the substance above one tonne per year and at least 12 months before the relevant registration deadline.

The last registration deadline for tonnage bands between 1-100tpa is on 31.May 2018. This means that the deadline to late pre-register a new substance and benefit from the extended deadline expired on 31.May 2017.

If you are a potential registrants who for the first time manufacture or import a phase-in substance in quantities of one tonne per year or more you have submit your inquiry dossier to ECHA. For further information, see Q&A 444.


If a dossier submission is rejected after the second technical completeness check, what are the consequences?
In case the registrant fails to complete his/her registration for the second time within the deadline set, the Agency will reject the registration and the registration fee will not be reimbursed. According to Article 5 of the REACH Regulation, substances may not be manufactured, or placed on the market unless they have been registered. By virtue of Article 23(1), 23(2) or 23(3) of REACH, as applicable, neither Article 21 nor Article 5 apply to the registration dossiers for substances benefiting from the extended registration deadlines of Article 23 of REACH until the respective deadline in question. This means that if a registration is rejected before the respective deadline in Article 23 of REACH, manufacturing or importing of this substance within the EEA can continue until this deadline.
How can I be updated with the latest news or the status of REACH-IT?

You are invited to consult the latest news from ECHA webpage. You can also subscribe to our weekly e-News and bimonthly Newsletter at  http://echa.europa.eu/subscribe

A confirmation email will arrive to your email account and after you confirm it your subscription will be activated. 

News on maintenance and other breaks in service will be communicated in the news section in REACH-IT at:

https://reach-it.echa.europa.eu.