Facilitation of Substance Information Exchange Fora
Concawe has volunteered as the SIEF Formation Facilitator for all petroleum substances, and for sulphur that require registration. This role has been recorded in the REACH-IT system of the ECHA. Concawe is therefore the only formal and official SIEF Formation Facilitator for petroleum substances and sulphur. Concawe intends to continue this role until the final registration deadline in 2018.
Concawe in its role as SIEF Formation Facilitator:
- Has surveyed to establish whether pre-registrants intend to follow up their pre-registration(s) by registration(s), in which volume band and by which of the three deadlines (2010, 2013, 2018).
- Has provided a SIEF communication tool.
- Has collected relevant and reliable substance data from registrants and other data holders
- Has initiated additional testing, i.e. testing that is required before registration
- Has formed the “Super-SIEFs”
- Has identified a Lead Registrant for each petroleum substance and sulphur (for most petroleum substances Concawe member companies have acted as Lead Registrants).
Concawe regards all pre-registrants who have not responded to communications from Concawe as the SIEF Formation Facilitator as “dormant”, i.e. as having no intention to register. This policy is being supported by the European Chemical Agency. In order to avoid pre-registrants missing this important information the following text has been posted in REACH-IT for petroleum substances and sulphur:
“Concawe is acting as the SIEF Formation Facilitator (SFF). Please note that no other SFF has been recorded in REACH-IT.
Should you intend to register this substance and not have access to the Concawe SIEF Communication Tool yet, please send an e-mail to the Concawe e-mail address firstname.lastname@example.org mentioning:
- In the subject line: Request for link to the Web Ordering Tool
- In the content section: Request receiving the link to your web ordering page clearly stating:
- your Legal Entity Name as indicated in REACH IT
- the UUID number of your Legal Entity in REACH-IT,
- your e-mail contact,
- the pre-registration number or inquiry (s),
- the CAS number and EC numbers of the substance you intend to register,
- the type of registration i.e. full substance or intermediate under strictly controlled conditions (REACH Arts. 17 & 18),
- the tonnage band in tons per annum 1-10, 10-100, 100-1000 > 1000,
- the registration deadline corresponding to the type of registration and tonnage band
This is to confirm that – in line with advice from ECHA – the SFF will regard as dormant all those pre-registrations for which no response has been received to any communication from CONCAWE. In other words, it is being assumed that these pre-registrants do not intend to follow up their pre-registration by a registration. These pre-registrants will therefore receive only limited information directly.
Should you have no intention of following up your pre-registration by a registration, we suggest that you deactivate your pre-registration. Your pre-registration can be re-activated later if needed.”
In addition Concawe will from time to time contact by e-mail all SIEF participants whose pre-registrations have not been deactivated in ECHA’s REACH-IT system.
The joint parts of Registration Dossiers will not only be made available to registrants of phase-in substances but also registrants of non-phase-in substances (i.e. new market entrants) who have gone through the inquiry process with ECHA in accordance with Article 26 of the REACH Regulation.