REACH consortia and SIEF
Under clear operating rules and transparent cost sharing mechanisms, the consortium members work together on the collection, evaluation, sharing and completion of the necessary data to complete and to submit the REACH registration dossier in time and cost efficiently.
The formation of a REACH consortium helps manufacturers and importers of chemical substances guarantee that their business interests remain protected.
A consortium is a form of cooperation between relevant stakeholders to structure how parties can work together for a certain purpose, in a effective manner and in compliance with the REACH legislation and European Competition laws. A consortium is often the safest way to submit a joint registration dossier and approach REACH registration.
Substance Information Exchange Forum
The REACH regulation introduces a Substance Information Exchange Forum (SIEF) primarily to share data among manufacturers and importers of the same substance.
A SIEF is a virtual platform gathering potential registrants of the same substance to facilitate the required data and cost sharing processes as well as to prepare a joint submission of certain data to the European Chemical Agency (ECHA). It enables the exchange of information between potential registrants and is also a platform to prepare jointly the data required for REACH registration. SIEFs help to minimise duplication of testing and aim to foster agreement on substance classification and labelling.
A SIEF is composed of companies that agree on the sameness of a chemical substance and therefore have the obligation to share vertebrate studies. SIEF participants react to requests, identify needs for further studies and arrange to carry them out. A SIEF is operational until 11 years after entry into force of the REACH regulation.
Potential registrants participating in a SIEF are free to organise themselves as they want in order to meet the obligations under REACH. They can use different forms of cooperation to do so, including the creation of a consortium.
Read more information on our SIEF Support Services
SIEF Leadership Team
When no consortium exists within a SIEF, a SIEF Leadership Team (SLT) advised to be formed in order to manage the SIEF on a day-to-day basis. The SLT would comprise of a few active members of the SIEF including of course the Lead Registrant. The SLT would be granted the permission to take decisions, assign resources manage the finances and invoicing as well as to monitor, control and report on the status of activities and deliverables of the SIEF.
How does a consortium work?
To carry out obligations under REACH, many companies have decided to organize themselves in consortia. Agreeing on a consortium agreement, the member companies are free to decide on its content, bearing in mind their legal obligations under European Union laws governing competition and under REACH.
In particular, it is crucial for the members of a consortium to establish a transparent organisational structure and rules regarding:
- membership
- allocation of tasks and responsibilities
- data valuation
- allocation of costs of cooperation
REACH Consortia can act on behalf of their members towards outside parties. Members of a consortium can decide to jointly submit technical data and a chemical safety report on a substance. Consortia usually have no legal personality. They are typically flexible and limited in scope and time. A consortium operates through several bodies, such as Steering and Technical Committees to give overall direction and take technical decisions. A Manager or Secretariat will ensure optimal management, resources and successful completion of the consortium.
Read more information on our Consortium Management Services