Q: We intent to register a substance, and there is another company is concerned with the same substance registration. We want to know the total fee for REACH registration on the substance. Could you please give a brief introduction of the computing method?

A: We calculate the total fee that is around 50000 euro. The exact cost of the registration is depending on specific data that substance provides. As Company A mentioned before, there are 2 companies interested in REACH registration on the substance, and therefore your company could prepare for a REACH registration as a member of joint submission* that is more efficient and cost-effective way. We will give you specific introduction about the computing method after communicating with our experts in laboratory. We suggest that your company could make pre-payment for substance registration firstly, and then our REACH24H Consulting Group will refund for any overcharge or demand a supplemental payment for any deficiency.

Q. The tonnage band in pre-registration is 100-1000tons. I wonder what if the tonnage of substance exceeds 1000 tons in registration.

A. If a substance already has pre-registered in tonnage band 100-1000 tons, while the real tonnage of substance exceeds 1000 tons, there are two solutions 1) If the registrant intent to register the substance immediately, he is allowed to register the substance with the pre-registration number according to real tonnage of substance. When it comes to the cost , it is required that the registrant should only pay a supplemental payment, such as registration fee (ECHA), data fee. Of course, REACH24H Consulting Group will charge a certain percentage of service fee. 2) if the registrant do not register immediately. Since the deadline of registration of substance >1000 tonnes per annum is 30^th October 2010, it is not allowed to change the tonnage band to 10000+. We still suggest registrant register the substance immediately, then re-read solution 1.

If the substance has registered in tonnage band 100-1000tons, the registrant could raise the tonnage after the registration, and he is obligated to submit and update the dossier required.

There are also some similar questions from companies, for instance, could registrant lower the tonnage band after registration? Actually, it is allowed for registrants to lower the tonnage band after registration with dossiers updated, while the registration fee (ECHA) would not be refunded, which will not be charged However, if registrant want to raise back to original tonnage band after that, the registrant has no need to pay for registration fee(ECHA) again. For example, the registrant registers a substance at tonnage band 100-1000 tons. After that the company stops the trade, and the business tonnage is 0, the registrant could lower the tonnage band without getting back the registration fee (ECHA). When he restarts the trade with the same tonnage band and registration number, the registration fee (ECHA) will not be charged again.

However, it is not recommended for companies to lower the original tonnage band. Compared with lower tonnage band, higher tonnage band usually has more test data required and longer test cycle. In addition, higher tonnage band covers lower tonnage band. Companies are not recommended to lower the tonnage band unless the real tonnage is 0 ton.

Q. After finishing REACH registration, how to protect our registration number from being used by other companies?

A. According to the report, 25 registrant’s numbers were once used illegally by other companies who get the registration numbers from different channels, such as staff turnover. In REACH24H Consulting Group, there is RSCC (REACH Supply Chain Compliance) system which was developed for work efficiency in REACH compliance. RSCC system has now been running active for one year with over 1000 supply chain actors, and it requires companies to register for every trade, with secured confidential setting, in order to get tonnage band coverage certificate（import certificate). The certificate would prove that the company did not transact registration number illegally but a victim, in case someone else get and use your registration number illegally without let you know.

Q. It is possible to change my only representative after pre-registration?

A. According European Chemical Agency’(ECHA) ‘Guidance on Registration’, the non European Union manufacture who has appointed an Only Representative to pre-register his substance can transfer that Only Representative if he is not satisfied with the service he is receiving from current Only Representative, and continue to benefit from the phase in registration deadline.

If a non-Community manufacturer decided to change his Only Representative and the previous Only Representative had pre-registered the substance originating from the non-EU manufacturer, then the successor should communicate the change of Only Representative to the Agency in order to continue to benefit from the phase-in deadline for registration of that substance.

However, there are some consulting companies distorting the article in the guidance deliberately to prevent customers transferring their ORs.

Q. ECHA, in July 2012, announced that they published certain information it holds on substances free of charge over the internet. How can we protect our business secret from being divulged?

A. The information released are mostly contained in SDS( Safe Date Sheet) , such as registration number, the identity of LE, and the decision made by ECHA is aimed to improve ECHA’s record on disclosure and transparency. However, it is believed that, to some extent, it will lead to business information divulged. According to ECHA, information shall be publicly disseminated unless the registrant has submitted a confidentiality claim and ECHA has accepted that claim.

If the companies from mainland of China do not expect the certain registration information to be publicly published on the website, they should request the Only Representatives (ORs) to update the registration dossiers, and to claim confidential on certain information. The documents required include 1) the justification of the information is CBI (confidential business information) 2) the justification of commercial value in protecting the information from being released. 3) the justification of the loss caused by dissemination of information about registrant or third part.

Q. We wonder whether or not the government will provide fiscal subsidy on new substance registration to company?

A. The authorities clarify that the subsidy policy is only available for Zhejiang province, and it is correspond with subsidy policy for SMEs. Besides, the amount of subsidy is different in different parts in Zhejiang province. In addition, sometimes it does not mean a remission for the total registration fee, but just a remission for service fee. It is better for company A to consult with local authority on this inquiry.

Q. Could you please briefly describe how to pay the total registration fee?

A. The total registration fee is composed of Data fee (LoA), service fee and registration fee(ECHA). The Data fee is paid to LR (leading registrant), service fee is paid to Only Representative, and registration fee(ECHA) is for ECHA. We suggest our customer paying the total fee in euro since LR in Europe and ECHA only accept payment in Euro or US dollar. If paying in Euro is not convenient for domestic company, customer could pay registration fee by RMB and transfer it into REACH24H’s Chinese account. Our subsidiary established in Europe will pay the fee on the behalf the company. However, payment in RMB will charge certain amount of service fee due to the tax and exchange rate.

Interpretation of key word *

Joint submission: in order to minimize animal testing and data fee for each registrant, some registrant are recommended to share data by the joint submission of registration data to ECHA. The principle is “one substance, one registration”.

During joint submission, the lead registrant or REACH consortium will do most of the work such as data collection, development of technical dossier and Chemical Safety Report (CSR), and submission of joint registration dossier to ECHA. Other co-registrants only need to pay the lead registrant or consortium a fee to refer to the joint registration dossier and then prepare the individual part of the registration dossier in IUCLID 5.