Competition has always been fierce in Europes lubricants industry, but the REACH program is compelling cooperation because only one dossier is accepted for each chemical on the registration list. Therefore, companies producing the same substance must form a substance information exchange forum to facilitate joint registration, said Pawel Figiel at the European Lubricating Grease Institute Annual General Meeting.

Helen Kean, technical director at Anthesis-Caleb and a member of the Chemical Hazards Communications Society, told LubesnGreases EMEA that SIEFs are mechanisms to bring potential registrants and data holders together to discuss substance sameness and identify whether any existing data can be used to fulfil the requirements of a registration dossier. A company becomes a member of a SIEF only when it has preregistered a substance, has submitted an inquiry or has data to share on the substance, she continued. When a supplier takes responsibility for the registration, downstream users need comply only with obligations pertinent to them.

Benefits to SIEF participants include increased knowledge about the substance, shared costs and the ability to avoid duplicate tests, noted Figiel, an ECHA scientific officer. Kean added during a panel discussion that REACH has created the need to communicate proactively within the supply chain.

However, cooperation can create challenges related to competition law. Kean explained that discussions within SIEFs are often among competitors, forcing them to work together in a potentially alien way. Sector associations existed prior to REACH, but they were generally generic, high-level discussions.

REACH forces companies to discuss specific substances; therefore, SIEF members must be careful to stay within competition law. At its simplest level, conversations around price and market dominance need to be avoided, Kean emphasized.

Companies can opt out of a SIEF over confidentiality concerns or disagreements on data, said Figiel. The opt-out can be full or partial, but may trigger a compliance check.

Figiel observed that the upcoming REACH registration deadline affects a higher percentage of small-to-medium size enterprises, and more SMEs are lead registrants. The ECHA is also seeing more small SIEFs and more registrants with no co-registrants.

Paul Whitehead, a chemical regulatory and toxicology specialist at WCA Environment consultancy, assured conference attendees that the European grease industry has anticipated the deadline. More than 30 grease thickeners are registered under REACH; however, he said that not every substance is covered by the consortium, so members must ensure their substances are registered.

Consortia agreements permit importers, manufacturers and Only Representatives to be signatories, explained Kean. Non-EU companies can participate through their appointed Only Representatives, who assume responsibility for REACH compliance. A principals role and participation in a SIEF or consortium can then be agreed between it and its Only Representative.

The need for REACH compliance will continue after the 2018 deadline, said Figiel. Registration of new substances, dossier updates and revisions to REACH are likely to continue.