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REACH Update: SIEFs and Consortia
Posted: February 12, 2008
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1. For how many substances from the ‘cosmetic ingredients’ sector do you expect SIEFs or consortia to be formed?
A: It is difficult to estimate this at this point. Most of the substances used as cosmetic ingredients are used in other application areas as well and the tonnages used for these other applications may be even larger. Therefore, I believe that for REACH processes, the substances used as cosmetic ingredients will be covered more often by other industry associations than by EFfCI. These associations will establish consortia for the substances. At this point, we assume that this will be the case for most of the cosmetic ingredients.
2. What will the procedure be for the exchange of data and the implicit financial compensation?
A: There are ongoing activities on an industry level to establish an electronic platform for the exchange of information within a SIEF. There will be no tools provided for this on behalf of the authorities. With respect to the financial compensation, it is requested in the REACH Regulation that this should be accomplished in a fair, transparent and non-discriminatory manner. Basically, the mode is open to be decided amongst the potential registrants from the industry. In a case of no agreement, the REACH regulation foresees a sharing of costs in equal parts.
3. How will confidentiality be ensured?
A: Within consortia the confidentiality rules will be defined amongst the participants. In order to achieve confidentiality within a SIEF a company can appoint a third party representative. In this case the identity of the company shall not be disclosed to the other registrants.
4. Will EFfCI take an active role in the REACH process and/or for the SIEFs?
A: The EFfCI board of management has decided to offer to its members support in the formation of consortia, if this is wanted. It is up to the member companies to nominate substances, where a common interest exists for the cooperation in relation to REACH requirements. The federation will get clarification on the interest and, where required, initiate the cooperation.
5. If consortia will be established for defined substances before June 2008, how will other suppliers of these substances be informed about the existence of the consortia?
A: Consortia are formed based on private agreements. According to REACH there is no request to form consortia and similarly there is no obligation to disclose the formation of a consortium to third parties.