유럽투자 InvestEurope.kr

Registrants who are part of a joint submission can decide to submit their Chemical Safety Report (CSR) jointly or separately. New Manual 19 ‘How to jointly submit Chemical Safety Reports’, outlines the principles which should be followed in that event.There are three key benefits of one CSR per substance. Firstly, users get harmonised and consistent exposure scenarios from all manufacturers and importers of the substance. Secondly, the CSR can address environmental exposure and potential risks in a scientifically sound way, based on the total manufacture and market volume. And finally, the authorities can evaluate one CSR per substance.

However, there can be complexities related to the preparation of a joint CSR. For example, in practice it may be challenging to organise communication among the registrants in a way that all the necessary detailed information on uses and conditions of use are exchanged with the lead registrant. It may also be difficult to determine the responsibility for the declarations on implementation and the communication of risk management measures in part A of the joint CSR.

To support the registrants, ECHA has produced Data Submission Manual 19 ‘How to jointly submit Chemical Safety Reports’, describing how to prepare and submit a joint CSR in the IUCLID 5 registration dossier.

See also: http://echa.europa.eu/reachit/joint_submission_en.asp

(Source: ECHA)