The Agency is thus adapting the submission interface in its IT system to indicate that third parties
who are not themselves manufacturers or importers can also take over the submission of group
notifications. Group notification can be done via REACH-IT. The relevant changes will be
implemented with the forthcoming REACH-IT release scheduled for summer 2012. Guidance
and other supporting documents will be updated in the following weeks.
If the C&L notification is submitted by a third party on behalf of a group of manufacturers/
importers, the submitting company will need to be able to document that it has been
mandated to act on behalf and in the name of the manufacturers/importers that are
part of the group and that the manufacturers/importers acknowledge that they remain
solely and fully responsible for fulfilling all their obligations associated with the notification.
The documentation related to the creation of this group of manufacturers/importers
together with the data and information on which the C&L is based, may need to be made
available on request to the national Competent Authorities or to the relevant Enforcement
Authorities.