Effectively navigate the SIEF arena
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To ensure you are ready to register your substances or products and negotiate within the SIEF arena, you need to form a picture of your portfolio and subsequent obligations under REACH. You will also have to make some choices about how your organization is going to comply with the new regulation. When establishing your obligatory lines of communication, you should consider not only your own level of participation, but also whether there are other parties that may represent you and keep an eye on your strategic interests.
Representation
You can continue to work alone or – if REACH is not part of your core tasks or if you do not want to reveal your identity – you can appoint a legal representative. You will have to decide which representation is most relevant and most appropriate for your organization. There are three possible types of representative:
Third-party representative:
- Representative of an unnamed registering party. This enables you to remain an anonymous party and it may make it more difficult for your competitors to distinguish your presence in a specific market.
Only Representative:
- EU-based legal entity appointed by a producing or formulating party based outside the EU. An Only Representative allows you, as a producer or formulator outside the EU, to take over the importing roles of all of your customers in the EU.
Third-party data holder:
- A university, laboratory or other interested group that owns research data about a substance. This representation allows you to share knowledge and possibly get compensated for it.
The challenge for you is to find out all of the options that are open to your organization so that you can choose which interests you are willing to devote yourself to wholeheartedly.
What can you expect from PwC?
- We can support you in developing a representation strategy and choosing the right type of representation.
- We can help you find a suitable representative third party.
- We deliver only representative services from our REACH Shared Service Desk
- We can provide access to the REACH Expert Network, initiated by PwC, which makes it easy to access procedure- and content-related expertise (including toxicological, IT and legal).
- We excel in setting up administrative systems that have an acceptable level of risk.
- We can also provide administrative support to ensure smooth communications and collaboration for efficient registration.
