Frequently asked questions
Please find below a set of frequently asked questions together with corresponding answers:
1. I received a notification that the Lead Registrant has updated the Lead Registrant Dossier. Do I need to update my individual registration?
The Lead Registrant has performed one major update to the Lead Registrant Dossier beginning of 2016 and there has been a change in legal entity for the Lead Registrant end of July 2016. If you have updated your dossier using our new documents in May 2016 or later, there is no need to update your registration.
A new step-by-step guidance document is currently being prepared to explain the steps to take when updating your Dossier.
2. Can I use the ethanol REACH dossier for registration under the Biocidal Products Regulation?
Due to our agreements with the data owners, our REACH dossier cannot be used for registration under the BPR. If you are interested in using ethanol for biocidal purposes or marketing it for that purpose, you can contact one of the two existing biocides Consortia for further information on the process. Below the contact details for both consortia:
ASD Consortium Alcohol
Chairman: Dr. Michael Wilz
Tel.: +49 (0) 5 21 / 30 37 – 310
3. What analytical tests are required by individual registrants to meet the analytical data requirements?
Please refer to the analytical guidance documents provided by the Consortium in the member's area of the website.
4. Do I need to submit a CSR individually?
Due to a mistake in the update provided by the lead registrant in 2013, the joint submission shows that both the CSR and the Guidance on Safe Use are submitted jointly. This should NOT be the case as it is intended that only the Guidance on Safe Use is submitted jointly. Indeed, the lead company CSR only covers ethanol use in fuel, so anyone not submitting their own CSR would not have other uses covered by their registration. Therefore we ask that all registrants submit their own CSR to ensure that their registration is fully compliant!
5. Are the documents of the association IUCLID-6 compatible?
We have issued IUCLID-6 compatible documents (November 2016). Adjusted guidance documents will be created in the near future.