It is reported in the news released by ECHA on 22 February that some companies falsely claimed to be lead registrants (LR) for certain substances. Here REACH24H Consulting Group would like to kindly suggest that companies give a second thought to the credibility of the claimed LR. According to the core principle of “one substance, one registration” of EU REACH, the election and determination of LR must follow specific procedures. The claimed LR identity can be problematic in that the nomination might has not been agreed between the co-registrants, another lead registrant could have been selected or even a joint registration has been already submitted. If you are approached by such a company, you should not accept their offer to prepare a joint registration, but to look for the real lead and other registrants of your substance. For the invitation from a claimed LR, be it true or false, it is always better for companies to turn to their Only Representative (OR) for confirmation.

Admittedly, the claimed LR might offer a quite appealing offer of LoA cost without a full conformity to the REACH rules. However, more often than not the dossier quality can be far from satisfaction, possibly triggering additional costs for the update of data later. Then what to do if a self-claimed lead registrant contacts you before you identified your co-registrants? Here below are some advices from the ECHA news for you to check their validity:

• Ask for details on the identity of the substance to establish substance sameness.
• Ask for evidence that they have the consent of the co-registrants to act as a lead registrant.
• Ask for evidence that they have sufficient information for a compliant dossier.

Also, if your company is experiencing difficulties in verifying the validity of the lead registrant, you can contact the ECHA Helpdesk for further advice and possible intervention. After all, the main task of the lead registrant is to submit the joint registration dossier containing all information needed for a compliant substance registration while it is the responsibility of all co-registrants to get access to data based on cost sharing.

As a pioneering consulting company in China to study on EU REACH, REACH24H has a professional team specialized in SIEF communication, boasting a long-time favorable communication with large chemical companies and associations as well as official experts. We have followed closely the registration updates of thousands of substances with pretty much experience in SIEF communication. Besides, the online SIEF Record System developed independently by REAHCH24H has greatly facilitated an efficient and accurate identification of the right LR for each substance, thanks to its accumulated comprehensive information from daily communication and consistent updates of each substance.

If you’re interested in more details about this topic, please send your queries directly to rscchelp@reach24h.com .