The requirement for companies to update their REACH registration dossiers ‘without undue delay’ is in most cases specified by the European Commission (EC) as 3 months. In more complex cases, the deadline for updates is up to 1 year. The clarification was made on Monday 12 October 2020, and it enters into force 60 days after the announcement.

The clarified rules are as follows:

• The 3-month deadline applies to administrative updates, e.g. change in a registrant’s status or identity

• The 6-month/9-month/12-month deadlines apply to ‘more complex updates’

  • Applies for example when there is a change in:

    • the classification and labelling of a substance without a harmonised classification

    • a chemical safety report

    • guidance on safe use

• When there are multiple reasons for updating a registration, only one submission is required and the 1-year deadline applies

• The 3-month deadline applies to inform that the manufacture or import of a substance has ended

About EU REACH

The REACH Regulation states that companies are responsible for collecting information on the properties and uses of the substances they manufacture or import above one tonne a year. Registration is based on the ‘one substance, one registration’ principle – meaning that manufacturers and importers of a substance have to submit their registration jointly.

In addition, companies have to assess the hazards and potential risks presented by the substance. This information is communicated to ECHA through a registration dossier containing the hazard information and, where appropriate, any relevant risk assessments.

Active monitoring required

The EC advises companies to ensure that they have monitoring systems in place that allow them to swiftly identify any changes that require them to update registrations. They also should keep records of past updates for all substances in case they are requested by national enforcement authorities. This applies also to jointly submitted registrations, which are the responsibility of all co-registrants (lead and members).

Support is available from Yordas’ chemical regulatory experts

• Learn more about our European REACH Regulation Services

• Yordas Hive is a comprehensive chemicals management solution that works with your data to bring you exactly the information that you need to stay compliant, and helps you save your valuable time.