Develop an application strategy

Develop an application strategy

If any of your substances are affected by authorisation, the next step is to develop a strategy for how to proceed.

You should

  • explore whether there are safer alternatives and assess whether it is possible to substitute to them, and
  • also assess the importance of the substance to your business and your supply chain.

If you decide that you need to continue using the substance or placing it on the market after the sunset date, you or another company in your supply chain will need to apply for authorisation by the latest application date specified in the Authorisation List.

Supply chain coverage

Manufacturers, importers or downstream users can apply for authorisation but there are differences in supply chain coverage depending on who applies. A granted authorisation covers the entire downstream supply chain of the applicant for the specific use. It also covers the applicant's immediate supplier (but only one step up the supply chain) as long as this supplier is not using the substance itself.

Supply chain communication is important to find out what others are planning to do and to potentially develop a plan together. The Partners' Service can be used either to find potential partners (such as companies, consortia, industry associations and consulting companies) or to add information about yourself so that others can find you.

Individual or joint application?

An application can be submitted by one applicant or a group of applicants (i.e. a joint application). Due to the possible complexity and technical issues of joint applications, ECHA recommends that you develop and submit a joint application when:

  1. all co-applicants of the group apply for all uses in the joint application for authorisation, and
  2. they have found an acceptable way to share all information provided in the application.

In complex cases, it may be preferable for each co-applicant to submit their own application separately.

Develop an application strategy