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REACHWise
REACH & CLP consultancy

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Pre-registration

The main pre-registration period was between 1 June and 1 December 2008. Having carried this out means you benefit from the “delayed” registration deadlines for your dossier. For a diagram click here.

Under specific circumstances you can submit a late pre-registration, which allows you to join in after 1 December 2008. Note that this option is only available to you if you meet certain criteria for this substance and the time frame within this needs to be done is limited. Contact us if you think you need this.

 

Registration dossier

Preparation of your registration dossier should start early.  We undertake this or manage your company’s registration. Our level of involvement is your choice: some companies want to involve their experts, others rely on scientific support or additional technical resources that we offer because they do not have them; this includes human health and environmental aspects. REACHWise adopts a flexible approach to accommodate your preference. We also offer Third Party Representative services, either as in the REACH legal definition or later to represent you on an ad-hoc basis.

Areas we cover – but some companies prefer to do some elements themselves – are as follows:

General Summary

To minimize animal testing and data fee for each registrant, REACH encourages data sharing among all registrants by the joint submission of registration data to ECHA. The principle is “one substance, one registration”.

During joint submission, the lead registrant or REACH consortium will do most of the work such as data collection, development of technical dossier and Chemical Safety Report (CSR), and submission of joint registration dossier to ECHA. Other co-registrants only need to pay the lead registrant or consortium a fee to refer to the joint registration dossier and then prepare the individual part of the registration dossier in IUCLID 5.

Registration under REACH - Joint submission

The default situation is that for each substance a single registration is completed through a joint submission of all registrants. Essentially the choice is to become a lead registrant or be part of the joint submission. We do not go into the details of this but contact us if you want to know what is involved and why you may want to consider this.

The requirements for a technical dossier are summarised above .. Find out more >>>.

A general summary is also given.

For the Chemical Safety Assessment and Chemical Safety Report (find out more >>>)

 

Lead Registrant

The lead registrant is responsible for the bulk of the dossier. He goes through the necessary steps as prescribed in the legislation to collect and prepare the joint registration dossier, which consists of the Technical Dossier and certain parts of the Chemical Safety Report. He submits this dossier through REACH-IT on behalf of the SIEF to ECHA.

 

Registrant or Co-registrant

As a member of the joint submission, the registrant prepares the individual parts of the joint submission. This needs to be done in IUCLID.  Having paid for the necessary access to the dossier of the Lead Registrant, the co-registrant has the right to refer to the common part of the registration dossier. Armed with additional security details of the joint submission, the co-registrant then submits his dossier through REACH-IT to ECHA.

 

Dossier submission

.... Lead dossier as part of the joint submission

.... Individual dossier as part of the joint submission

None of these tasks are simple, but we provide you with dedicated and professional support to ensure your dossier is complete and correct, submitted on time to ECHA.

Registration

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