How to cooperate for REACH registration – best practice for SMEs and consultants

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External service providers or consultants can be crucial for SMEs managing their regulatory obligations. Preparing a REACH registration requires time, effort and expertise – resources that smaller companies do not necessarily have available to use beyond their regular business duties. Hired help can be a worthwhile investment. The tips below are for SMEs and consultants alike to assist cooperation in successfully registering under REACH.

Tips for SMEs

 

1. Define why you need a consultant

Do you want advice on the registration process or someone to do the actual work for you? Or do you need help with certain elements of the work, for example, the development of a testing strategy or the preparation of a IUCLID dossier? Do you need a consultant to train your co-workers?

Make sure you have clearly defined objectives for the external service you wish to buy.

 

2. Learn the basics

Like any regulation, REACH has its own language and terminology. It is worth investing in understanding the basics, so that you can effectively communicate with the service providers.

ECHA’s REACH registration support has been developed with less experienced companies in mind – the more knowledgeable you are, the fewer misunderstandings there will be. Also, have a look at our Practical guide for SME managers and REACH coordinators before you start.

 

3. Be ready with the basic information

For the consultant to be able to assess how they can best help you and at what cost, you need to give them the basic information on:

  • the substances to be registered (name, CAS number, EC number);
  • the annual manufacture or import tonnages (relevant for the data costs and registration fee);
  • your role under REACH (manufacturer, importer, formulator);
  • your company size, with documentary evidence;
  • the substance identity (needed to determine whether a lead registrant already exists);
  • the manufacturing process, if your substance is a UVCB;
  • the availability of existing analytical, physico-chemical, toxicological and ecotoxicologial data, or access to this data;
  • how the substances are used by your customers.
If the consultant is your only representative, give them the information needed to fulfil the only representative duties (Article 8 of REACH).


If you are a non-EU company and the consultant is your only representative, make sure you have clearly agreed on the terms and conditions of the cooperation, including a possible change of the only representative.

 

4. Select the appropriate service provider

The basic information that you give service providers enables them to make offers that you can then compare to find the best deal. You can also ask for references and background information on the consultants to make sure they have experience and knowledge of how the legislation works.

Consultants who are members of different associations very often undergo a critical evaluation by their association. Some have certificates or proof of training according to established quality standards.

Also make sure that the consultant has the necessary resources to complete the work for you in the agreed time frame.

See our Checklist to hire a good consultant for more details.

It takes time and money to prepare and maintain a good registration dossier. You will not get quality services at very low prices under tight deadlines.

 

5. Start early, be on time

Start the registration process and hire help early so that there is enough time for building constructive and solid cooperation and completing all the steps needed for a successful registration.

To ensure that the agreed timeplan holds, you need to respond to the consultant and provide material as and when agreed. Delays on your side will translate into delays on the consultant’s side, and may ultimately affect the success of your substance registration.

 

6. Work with IUCLID Cloud to share information

Ask your consultant to use IUCLID Cloud for SMEs to prepare your registrations.

This will enable you to collaborate with full transparency, as you can easily grant your consultant access to your account and you can both work online, at any time and from anywhere, on the same registration data.

Also, your data is stored safely at ECHA. Automatic updates ensure that you will always be able to work with the latest version of IUCLID, with fully managed back-ups and 24/7 availability of the service.

The interface of IUCLID Cloud is simpler than that of the full desktop version, as it has been specifically designed for use by SMEs.

If you do not want to share your IUCLID data with your consultant or if you agree that the dossier is to be prepared somewhere else, make sure that the final data set and dossier is handed over to you after the work is completed. Storing these in your IUCLID Cloud account will be useful when you need to update your registration dossier.

 

7. Consider your post-registration obligations

You need to keep your data up to date and reply to any potential requests for additional information from ECHA, for example, during the evaluation process.

Make sure the post-registration work is covered in the consultancy contract, including your access to the IUCLID data. It is important that you retain copies of the full data set and dossier in your IUCLID Cloud account even after they are submitted, so that you can continue to manage your IUCLID data at a later date.

Remember also to keep your contact details up-to-date in REACH-IT, check your REACH-IT account for any messages from ECHA and inform your consultant about them. You can also agree to add the consultant's email address to REACH-IT so that they receive notifications directly themselves.

Tips for consultants

 

1. Be transparent

Be clear on what you offer and at what cost. Your offer should transparently detail the services included, their pricing, the payment schedule, how to cancel the contract, agreements about the use of the client’s budget, with possible deviations, and rights granted to the client company.

Set up a system to transparently monitor the progress of the project.

Offer a free first screening appointment.

 

2. Be the expert

Make sure you understand the different processes of REACH and are up to date with the latest information. Follow ECHA’s news so that you do not miss any important notifications or updates.

It is particularly important to fully understand the testing requirements and how data and cost sharing works, as inadequate knowledge in these areas could mean extra costs for your client.

As your client might not be a REACH expert, be prepared to take the time to explain in layman’s terms the requirements for registration.

 

3. Be the problem solver

REACH offers multiple solutions to a particular issue. You need to be able to analyse your client’s situation broadly and offer solutions that are relevant to them.

It’s good to keep in mind that nobody knows everything. You may need additional help and outsource some tasks to another service provider. However, this then needs to be taken into account in the schedule.

 

4. Make a plan, communicate and listen

Make a clear plan for the project and its budget to make sure your client fulfils their obligations in time and can stay legally in business. Demonstrate to your client that you have the resources necessary to do the job.

Establish good two-way communication channels, be open and remember to listen. If you have many staff, appoint a single contact person for your client.

Be ready to look for ways to adjust your working style to each client’s specific schedule, budget and overall requirements.

 

5. Understand your role and responsibility

Make sure your client knows your abilities and capabilities, making clear what you can and cannot do, so that there are no false expectations or misunderstandings. In the end, your EU/EEA client is responsible for their registration.

If you are an only representative for a non-EU company, make sure your customer knows what exporting to the EU/EEA entails under REACH and is able to help you fulfil your duties as described in Article 8 of the regulation.

If you are a third party representative for a company that does not want to disclose their interest in a particular substance through participation in the substance information exchange forum (SIEF) or a consortium, ensure that you have clear instructions from your client for each situation that you represent them in.

If your client continuously fails to hold up their part of the agreement, consider the possibility of cancelling the contract.

 

6. Work with IUCLID Cloud to share information

Use IUCLID Cloud for SMEs to prepare your client’s registration dossier. By using it, you can increase the transparency of the registration process and collaborate easily with your customers on the registration data.

With IUCLID Cloud Trial, you can organise trainings on the use of IUCLID.

 

7. Maintain your reputation

Protect your public reputation, as it is not easy to repair if damaged. Fulfil your duties of care to the highest levels of accountability, responsibility and integrity.

This web page was developed in cooperation with two consultancies.

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