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Guidance on registration - ECHA - Europa

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<str<strong>on</strong>g>Guidance</str<strong>on</strong>g> <strong>on</strong> registrati<strong>on</strong><br />

Versi<strong>on</strong> 2.0 May 2012 59<br />

explanati<strong>on</strong> of the process to be followed and the tasks to be performed as well as the<br />

reference documents to be c<strong>on</strong>sulted.<br />

3.3 Joint submissi<strong>on</strong> of data<br />

Although each registrant is obliged to submit his own registrati<strong>on</strong> dossier for each of his<br />

substances, in cases where a substance is manufactured or imported or intended to be<br />

manufactured or imported by more than <strong>on</strong>e company, they are required to submit certain<br />

informati<strong>on</strong> together. The joint submissi<strong>on</strong> of data applies both for the registrati<strong>on</strong> of phase-in<br />

substances and that of n<strong>on</strong> phase-in substances.<br />

Registrants are required to jointly submit informati<strong>on</strong> <strong>on</strong> the intrinsic properties of<br />

the substance (studies and testing proposals, if any) and its classificati<strong>on</strong> and<br />

labelling and can, if they agree to do so, also jointly submit the guidance <strong>on</strong> safe use<br />

and the chemical safety report (CSR) (Article 11). The intenti<strong>on</strong> is that registrants will<br />

save m<strong>on</strong>ey by co-operating <strong>on</strong> the preparati<strong>on</strong> of the dossier and also to reduce the need for<br />

testing, in particular <strong>on</strong> vertebrate animals. In additi<strong>on</strong>, registrants submitting a joint<br />

submissi<strong>on</strong> benefit from a reduced registrati<strong>on</strong> fee. For additi<strong>on</strong>al informati<strong>on</strong> <strong>on</strong> how to gather<br />

and share existing informati<strong>on</strong> see also secti<strong>on</strong> 4.<br />

It is important to stress that in case an <strong>on</strong>ly representative has been appointed by a n<strong>on</strong>-EU<br />

manufacturer to carry out the registrati<strong>on</strong> of the substance, he shall be part of a joint<br />

submissi<strong>on</strong> with the other manufacturers, importers and <strong>on</strong>ly representatives for the same<br />

substance.<br />

The requirement to make a joint submissi<strong>on</strong> also applies if a given substance is a phase-in<br />

substance to some of the registrants and a n<strong>on</strong> phase-in substance to others. It also applies<br />

regardless of whether the substance has been pre-registered by all, some or n<strong>on</strong>e of the<br />

registrants.<br />

Note that the joint submissi<strong>on</strong> of data does not eliminate the obligati<strong>on</strong> for each registrant<br />

(manufacturer, importer or <strong>on</strong>ly representative) to also submit an individual dossier.<br />

3.3.1 Mechanisms of joint submissi<strong>on</strong><br />

The informati<strong>on</strong> that needs to be submitted jointly is submitted by <strong>on</strong>e lead registrant <strong>on</strong><br />

behalf of the other registrants (the so-called ‘member registrants’). Other informati<strong>on</strong> needs to<br />

be submitted by all registrants individually. The lead registrant of a joint submissi<strong>on</strong> could, for<br />

example, be the largest producer as he in any case will have to register the entire data set by the<br />

earlier deadline. However, this is not obligatory: the joint submissi<strong>on</strong> registrants have the possibility<br />

to appoint a lead registrant with a lower t<strong>on</strong>nage (for instance, if they have to prepare joint<br />

submissi<strong>on</strong>s for more substances and decide to share the workload of managing the joint<br />

submissi<strong>on</strong>s). If they arrange their joint submissi<strong>on</strong> in this way, a lead registrant in a lower t<strong>on</strong>nage<br />

band has to provide a complete dossier (i.e. with studies for the highest t<strong>on</strong>nage band to be<br />

registered for that substance) meeting the earliest deadline applying to any of the registrants. It is<br />

important to stress that the lead registrant will always pay the fee corresp<strong>on</strong>ding <strong>on</strong>ly to his own<br />

t<strong>on</strong>nage band, as well as any other member of the joint submissi<strong>on</strong>.<br />

In practice this implies that there will be two different types of registrati<strong>on</strong> dossiers: the ‘lead<br />

dossier’ (c<strong>on</strong>taining the informati<strong>on</strong> of the lead registrant and the data set required in REACH<br />

for the highest t<strong>on</strong>nage band to be registered for that substance) and the ‘member dossier’<br />

(with the individual informati<strong>on</strong> to be submitted by each member of the joint submissi<strong>on</strong>). The<br />

informati<strong>on</strong> requirements for each type of registrati<strong>on</strong> dossier are shown in Table 3 below.<br />

Annankatu 18, P.O. Box 400, FI-00121 Helsinki, Finland | Tel. +358 9 686180 | Fax +358 9 68618210 | echa.europa.eu

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