CHEMICAL PRODUCT DEVELOPMENT AND DEFENSE

Third Party Representative

Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Article 4 affords European Union entities -- manufacturers, importers, and downstream users -- the ability to appoint a Third Party Representative (TPR) and thereby maintain anonymity in the context of data- and cost-sharing discussions with other parties (e.g., other Substance Information Exchange Forum (SIEF) participants). This convention is particularly useful for companies that, for commercial or other reasons, do not wish to signal to potential or actual competitors their company’s interest in a particular substance.

Although the appointing company retains full responsibility for complying with its REACH obligations -- for example, it remains the pre-registrant and potential registrant and must share, through its TPR, any existing data in its possession -- REACH makes clear that when a TPR has been appointed, the company’s identity shall not normally be disclosed by ECHA.

According to ECHA guidance, data holders wishing to participate in a SIEF for the purpose of sharing their data and seeking compensation also may appoint a TPR.

The Acta Group EU, Ltd (Acta EU) understands well the importance of protecting confidential information, whether it be product-specific information or corporate identity, and is uniquely qualified to serve as your company’s TPR under REACH. Acta EU offers a technical and commercial awareness developed from the experience of working in international consortia with such schemes as the International Council of Chemical Associations High Production Volume, representing our clients best interests in the formation of consortia, discussions and negotiations with consortium members and regulatory authorities, establishing contracts for data sharing, and assessing data for suitability of use under REACH.