REACH joint submissions

ECHA encouraged Lead Registrants (LR) to submit their dossiers as part of joint submissions by the end of September. This would enable the lead dossier to undergo the business rules and completeness checks swiftly to allow for any re-submissions before the November deadline.

As a joint submission member you must then create your own IUCLID 5 dataset. It is critical for you to have a clear understanding of who is providing which information; the LR takes the responsibility to create an IUCLID 5 dataset containing all REACH requirements related to the maximum tonnage band within the joint submission. This should include classification and labelling, study summaries, robust study summaries and testing proposals. As a joint registrant you may decide to submit guidance on safe use (section 11 of IUCLID 5) and a chemical safety report (CSR) individually or jointly.

In IUCLID each member will need to complete:

• Section 1 - General information
• Section 3 - Manufacture use and exposure

The following sections should be left empty:

• Section 2 - Classification and labelling
• Sections 4, 5, 6 and 7 - Endpoint sections

IUCLID sections which can be submitted jointly (only in the lead dossier) or separately (in the lead dossier and in the member dossiers):

• Section 11  - Guidance on safe use
• Section 13 - Chemical Safety Report (CSR)

As part of the joint submission you are required to submit your dossier via REACH-IT. The chronological order for submissions is the LR will submit the lead dossier for the joint submission first and only once the dossier has passed the business rules check can the members submit their joint dossier. The member dossier will then go through the same checks as the lead registrants i.e. business rules, fee paying etc.. If all is successful you will receive your registration number via your REACH-IT account.

Compiling a joint dossier can be a lengthy affair and an in-depth knowledge of the ECHA guidance will be required to successfully pass the business rules and technical completion checks.

JSC have had a great deal of experience compiling both lead and joint REACH dossiers with many clients having received their registration numbers. If you require any help in compiling either lead of joint dossiers please do not hesitate to contact us.

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