On July 13, 2022, European Chemical Agency (ECHA) announced that a second screening project to check companies are keeping their EU REACH registrations updated will be launched soon. The project will focus on substances with a harmonised classification (listed in Annex VI to the EU CLP regulation) and labelling (CLH) and will look at registrations where this information is not used correctly. Cases where incompliance is suspected will be passed to national enforcement authorities.

The results of ECHA’s first screening project, which focused on registrations of substances that are on the REACH Authorisation List, will be published next autumn.

These projects remind registrants of their obligation to keep their EU REACH registrations up to date.

Changes that Impact Your Dossier Updates

The EU REACH registration dossier has to reflect the current knowledge on how your substance can be used safely at production sites and by users throughout the supply chain. This means that after you have successfully submitted a registration and received your registration number, you still have work to do.

You have to update your registration – or contribute to the update of the joint part of your registration when:

1. Your knowledge on the substance or its use changes e.g. higher tonnage band, new uses, change in composition of the substance, etc.
2. You receive an evaluation decision requesting you to add information to your registration.

Changes in information requirements for registering chemicals under EU REACH, might have an impact on your dossier updates. You should also pay attention to the changes of the harmonised classification (listed in Annex VI to the EU CLP regulation) and labelling (CLH) of hazardous substances which is updated through an Adaptation to Technical Progress (ATP) and issued yearly by the European Commission.

Why Should You Keep Dossier up to Date?

ECHA performs IT screening campaigns on dossiers in order to highlight the aspects of registrations that can be improved, which reminds registrants to perform an update of their registration dossier under EU REACH to address the highlighted concerns, as well as to improve the quality of data in future EU REACH regulatory compliance. As a registrant, you should consider your dossier as a ‘living document’ and update it whenever new information is available.

Reference Links

ECHA’s Notice

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