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The SIEF formation facilitator (SFF) is not formally recognised in the REACH Regulation, while the lead registrant (LR) is specifically foreseen and necessary for joint registrations.
Acting as an SFF is voluntary and not legally binding, i.e. the legal entity volunteering is taking the initiative to contact the others within the pre-SIEF. Potential registrants are not obligated to use a SFF to form a SIEF. They may even bypass the SFF to begin pre-SIEF discussions, if the SFF does not act.
In contrast, the SIEF must select a lead registrant who submits the joint registration before the other registrants in the SIEF can submit their individual (“member”) dossiers for registration.
Additional guidance on the role of the SFF is provided in the Guidance on data sharing http://echa.europa.eu/guidance-documents/guidance-on-reach.