Member registrants – is your substance identity affected by a compliance check?
ECHA is sending informative letters to the members of joint submissions in which the lead, or any other member, has received a draft compliance check decision concerning substance identity. The aim is to make all the members aware of the ongoing process, which may eventually have an impact on the identification of the substance agreed in the substance information exchange forum (SIEF).
Helsinki, 17 March 2014 – The letters, sent through REACH-IT, inform registrants that a draft decision has been sent to one or more members of the joint submission. They include the date on which the draft decision has been sent and the deadline by which the recipient has to provide comments. Even if the draft decision does not affect the registration of other members, it may impact the substance sameness assessment made in the SIEF and ultimately the joint submission.
Therefore, ECHA encourages each member of the joint submission to contact the lead registrant and other members to assess whether the draft decision has implications for their registration.
The Agency reminds that it is the registrants' responsibility to make sure that the identity of the imported/manufactured substance is correct in their registration. Companies will need to update their registration if they conclude that the submitted information is inconsistent or if it does not meet the information requirements specified in Annex VI of the REACH Regulation.
The letters do not contain any confidential information, for example the text of the draft decision or the registrants' details. Also, as SIEFs are independently managed by industry, the Agency does not have a role in the discussions of the joint submission - for example in case of unresponsive members.