How to make changes to joint submissions

When a joint submission has been created in REACH-IT, it is sometimes necessary to make changes, to correct mistakes or to adapt to a new situation.

The lead registrant of the joint submission can make some changes to the joint submission, but changes to the following information have to be made by ECHA. To request the change, you need to contact ECHA through the contact form.

 

Change of lead registrant

Co-registrants can transfer the lead registrant role in REACH-IT if the previous lead registrant and the new lead registrant agree. The new lead registrant will need to resubmit the lead registration dossier to finalise the transfer of the lead role.

There are two situations where ECHA can reassign the lead role.

  1. If the role of lead registrant in REACH-IT has been taken on by a company that does not have the consent of the (potential) co-registrants and is not willing to transfer the lead role, you can request ECHA to perform a lead role verification. ECHA will then ask all (potential) co-registrants whom they have nominated as lead registrant. If it is clear from the replies that a company other than the current lead role holder has been nominated, ECHA will reassign the lead role in REACH-IT to this company, according to the wishes of the (potential) registrants. You should only request this verification if the co-registrants are able to clearly indicate which company has their support for the role of lead registrant.
  2. If the lead registrant is no longer responding to your communications, for example, due to bankruptcy, death or some other reason, the co-registrants can nominate a new lead registrant. You can request ECHA to reassign the lead role in REACH-IT. You will need to submit evidence on the nomination of the new lead registrant. Before reassigning the lead role, ECHA will contact the unresponsive lead registrant.

 

Jointly submitted documents

The guidance on safe use and the chemical safety report can be submitted by the lead registrant on behalf of all the members or, alternatively, separately by each registrant.

If you, as the lead registrant, have indicated that these documents are submitted jointly in the lead registrant dossier, you cannot change this later. However, if all the members of the joint submission have indicated in their dossiers that they provide these documents separately, you can request ECHA to change the status of these documents. Before you can make your change request, to ensure consistency, members may need to update their dossiers.

 

Type of joint submission

As of summer 2016, there are two types of joint submissions – ‘full’ and ‘intermediate’. A ‘full’ joint submission can contain any combination of full (standard) registrations and intermediate registrations. An ‘intermediate’ joint submission must only contain registrations for a substance used as an intermediate that is (manufactured or) used under strictly controlled conditions. Having one ‘full’ joint submission and one ‘intermediate’ joint submission for the same substance does not breach the joint submission obligation.

As a lead registrant, you indicate the type of joint submission in REACH-IT when you create it – and you cannot change it afterwards. However, you can request ECHA to change the type of the joint submission if all registrations fit the new type and no joint submission of that type already exists.

 

Tonnage band of the joint submission

The lead registrant indicates the tonnage band of the joint submission in their lead registrant dossier. This determines the information requirements that need to be fulfilled by the information submitted jointly in the lead registrant dossier. Members of the joint submission cannot register for a higher tonnage band, unless they submit the required additional information as an opt-out.

As a lead registrant, you can increase the tonnage band of the joint submission yourself when you update the lead registration dossier, but you cannot decrease it. However, if all members of the joint submission (excluding the lead registrant) have registrations in a lower tonnage band, you can request ECHA to decrease the tonnage band of the joint submission. Members may need to update their dossier before you can make the change request.

Once ECHA has decreased the tonnage band, you have to update the lead registrant dossier, indicating the new tonnage band for the joint submission. You must not remove any data satisfying the information requirements for the higher tonnage band, as you have the obligation to provide all data you have on the substance and this data was already available.

 

 

Name of the joint submission

As a lead registrant, you choose the name of the joint submission when you create it in REACH-IT and you cannot change it afterwards. In cases that are justified, you can request ECHA to change the name.

 

Deletion of an empty joint submission

The lead registrant can delete a joint submission they have (mistakenly) created in REACH-IT as long as none of the co-registrants have submitted their dossiers (successfully or not). If a lead registrant does not delete the empty joint submission mistakenly created, the actual registrants of that substance will afterwards not be able to create the joint submission and register. If this happens, you can ask ECHA to delete the abandoned joint submission.

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