Registration is a long and complex process, here are the 7 key steps in the procedure.
1. Inquiry file
2. Communication in SIEF
3. Joint/individual submission
4. Data sharing
5. CSR preparation
6. File preparation
7. File submission
Registrants manufacturing / importing substances above 1t/year must submit an inquiry dossier to ECHA. The dossier is made with IUCLID and submitted via REACH-IT.
As far as the substance is concerned, remember to check whether it is exempt from registration under Annexes IV and V of the REACH regulation.
This 1st step will enable you to be attached to a SIEF.
Substance Information Exchange Forum
1 substance = 1 dossier
SIEF members (Main Registrant, Active, Passive and Dormant) must identify the substance, establish a classification and uses covered by the registration
A lead registrant submits a dossier containing information common to all registrants for the substance concerned. Members, as co-registrants, submit a separate dossier for the same substance, including only the data specific to their own situation, without the shared information.
Sharing data avoids the need to produce new tests (on living organisms) and enables costs to be shared. Missing tests must be performed to complete the data.
As the main registrant or as a member registrant, you must check the analytical data to be supplied for your tonnage band.
A technical dossier complying with Annexes VII and VIII is required for quantities exceeding 1 tonne per year. When quantities exceed 10 tonnes per year, the preparation of a CSR becomes mandatory, including hazard assessment, exposure analysis and risk characterization.
Analytical data must be recorded in the IUCLID-6 software. The registration dossier is extracted from the software and submitted on the REACH-IT platform to the company's account. ECHA verifies that all fields have been filled in.
An invoice with the ECHA fee is issued. You have two and a half months in which to pay the invoice. If you fail to pay the invoice within this time, you will be obliged to submit a new dossier and the fee will not be refunded.
Once the invoice has been paid and the transfer received by ECHA, you will receive (on REACH-IT) a document confirming your registration and informing you of your registration number.
Your registration number certifies that your company is REACH-compliant for the substance concerned. Registration implies regular updating of your substance information, particularly for the tonnage band.