What you should know when deciding about your role in the SIEF

I. The different categories of SIEF members are as follows:


Potential Registrants

§        Current and potential manufacturers and importers of phase-in substances having pre-registered that substance

§        Current and potential importers of preparations containing phase-in substances, having pre-registered that substance

§        Current and potential producers and importers of articles having pre-registered that phase-in substance if intended to be released from articles.

§        Only Representatives of non-EU Manufacturers having pre-registered that phase-in substance


If you are a Late pre-registrants (first time manufacture or import > 1 tonne per year after 1 December 2008 – see Article 28(6) of the REACH Regulation)


Third Party Representatives

Manufacturers/importers of phase-in substances who have pre-registered these substances and Producers/Importers of articles who have pre-registered phase-in substances intended to be released from an article can decide to appoint a Third Party Representative to hide their identity vis-à-vis the other SIEF members.

When this happens, the Third Party Representative will be a SIEF member, but this does not mean that he then becomes a Potential Registrant, as the legal entity nominating a Third Party Representative retains the full legal responsibility for complying with his obligations under REACH. However, the Third Party Representative will carry out all proceedings under Title III of the REACH Regulation ‘Data Sharing and Avoidance of unnecessary testing’.


Data Holders who have expressed their intention to share data via REACH IT:

Data holders will join the (pre-) SIEF via REACH-IT following ECHA publication of the list of pre-registered substances before 1 January 2009. They may be:

§        Manufacturers and Importers of phase-in substances in quantities of < 1 tonne per year who have not pre-registered.

§        Downstream Users of phase-in substances.

§        Third Parties holding information on phase-in substances:

§        Trade or industry associations, sector specific groups and consortia already formed.

§        Non Governmental Organisations (NGOs), laboratories, universities, international or national agencies.

§        Manufacturers of a substance who have no interest in registering a substance under REACH because they do not produce or place it on the market in Europe (e.g. a non-EU manufacturer who does not export into the EU).


Data Holders who automatically join the SIEF

These data holders only will participate in data sharing, classification and labelling discussions and preparation of data for joint submission

          Àƒ Any manufacturer/importer who has registered a phase-in substance before June 1, 2018, even without pre-registration. (Early Registrants)

          Àƒ Parties that submitted information in the framework of the Plant Protection Product Directive (91/414/EC) or the Biocidal Product Directive (98/8/EC)



As there are no checks in the REACH-IT system, anyone can pre-register. It is therefore possible that a (pre-) SIEF contains members that are not described above.


Note: Data holders that have not informed ECHA of their intention to share data will not be SIEF members but may represent a source of data for potential registrants.


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CaSi has been registered on its own for REACH in 2010

the position paper of the CaSi Institute can be found under Position Papers section