Why registrants’ information has been made public?

Based on the cases REACH24H has been through, registration information has been published on the ECHA website is probably because

1)In a registration dossier submitted by Only Representative on behalf of a non-EU manufacturer, no EU importer information and no confidential claims for OR information (if a registrant is manufacturer himself, then here no confidential claims for registrant information).

Example:

• Individual registration

Both Company A appointed REACH24H as the Only Representative for substance a, the dossier of Company A contains no EU importer information and no confidential claim for OR information, then the OR name and registration information have been published.

• Joint submission

The rules for opt-out case also applies to co-registration. Only the registration number and OR name of those companies with no EU importer information have been published.

2)In a registration dossier submitted by Only Representative on behalf of a non-EU manufacturer, confidential claim for EU importer information in section 1.7 has been submitted but no claim for OR information.

Example:

Company B submitted confidential claim for EU importer information, so now no related information has been public.

Why registrant’s information has NOT been made public?

On the contrary, REACH24H Consulting Group has also been aware of some absence of registrants’ information from ECHA website. By communicating with ECHA helpdesk, we believe the reasons for that would probably be

1)Information including company names from dossiers submitted at the end of October is still being processed before its publication.

2)Confidential claim for section 1.1 (if confidential claim for section 1.1, then section 1.7 of EU importer information will be remained unreleased simultaneously) in the registration dossier submitted by Only Representative has been submitted.

3)Only Representatives (ORs) do not necessarily supply the substance and they have the possibility to indicate in section 1.7 of the IUCLID dossier who the actual suppliers (importers) are. If the OR chooses to have the supplier’s name disseminated instead of their own, the OR has to obtain and attach in section 1.7 the agreement by the supplier for the dissemination of their company name. Now ECHA is awaiting confirmation of consent from the supplier. In that case, ECHA will not publish company name and registration.

Example: In the registration dossier of Company A, EU importer information is contained in Sectoion1.7, and at this stage no confidential claim for either OR or EU importer. Now registration number is available on ECHA website with no OR information.