Chemical Safety Report (CSR) – Common or individual

Members of a consortium or a SIEF have to decide if the CSR is part of the Joint Submission or not (Article 11.1). There are three different procedures to choose.

1. Joint CSR for all registrants:

The Lead Registrant submits Part A and Part B in behalf of all members of the joint registration.

This procedure has the advantage that there is only one CSR for the substance and all information is submitted comprehensively.

It shows, however, disadvantages by being intricately when changes, updates or new registrants’ uses have to be added because additions to the registration dossier has to be done via the Lead Registrant. Moreover, in order to comply with competition law, trustee services may be necessary.

2. Partial Submission of a Joint CSR

The Lead registrant submits part B of the CSR jointly for all registrants and ticks the box for “Joint submission” in IUCLID, the registration software of the European Chemical Agency (ECHA). Then, every registrant submits individually part A of the CSR.

Furthermore, individual uses that are not covered by the Lead CSR Part B, can be added in a CSA by every registrant himself. Consortium members can also arrange that every joint registrant submits his own CSA for his uses when the Lead Registrant does not disclose his own uses and exposure scenarios.

This proceeding has the advantage that, if any updates or changes occur in a company, the Lead Registrant is not affected or involved in any administrative work.

3. Individual submission by every registrant

Every registrant submits CSR Part A and Part B on his own.
Lead Registrants or consortia may support their member registrants by providing a template of the common contents of the CSR.