Do EU REACH need to register?

The following behaviors in the supply chain must comply with the registration process:

EU manufacturers and importers in their own substances or mixtures

Eligible articles from EU producers and importers explain the guidelines for substances in articles

The "sole representative" was established in the EU and appointed manufacturers, formula or article manufacturers outside the EU to fulfill the registration obligations of importers

REACH registration - data sharing

A basic aspect of REACH is the requirements of the EU for the production, import, marketing and use of substances for information sharing. In this way, registrants of the same substance can reduce costs and avoid unnecessary vertebrate tests. When information is available, studies involving vertebrate tests must be shared between registrants to prevent repeated tests. The new research involves vertebrates only as a last resort.

Data sharing is also jointly registered before a substance is produced or imported by more than one company.

There are two mechanisms for data sharing:

Substance Information Exchange Forum (SIEF Forum), used for pre-registration of phased substances

Query, used for non-phased substances and substances whose phases are not pre-registered

The registrant must make every effort to ensure the sharing of information. The cost of joint registration is determined in a fair, transparent and non-discriminatory manner. All parties must fulfill their data sharing obligations in a timely manner.

REACH registration - data sharing dispute

RECHA can help resolve disputes between existing and potential registrants in data sharing. A person who claims that he can only use it as a last resort to initiate all possible ways between the parties has explored.

Any data sharing disputes and ECHA decisions raised by potential registrants must always be submitted to ECHA before registration.

In case of disputes, ECHA's decision will reach an agreement based on the efforts of both parties. The cost of shared data will be assessed in a fair, transparent and non-discriminatory manner.

Starting the data sharing dispute procedure with ECHA must show the efforts made by all parties of a potential registrant to reach an agreement and provide corresponding written evidence.