ECHA has recently launched two awareness campaigns aimed at improving compliance with REACH dossier update obligations, reminding registrants that REACH compliance is not a one-time activity but an ongoing responsibility.
Those familiar with the REACH Regulation (EC) No 1907/2006 will be aware that, in accordance with Article 22, registrants are responsible for proactively updating their own registration without undue delay whenever new information becomes available. The meaning of “without undue delay” was clarified further in Commission Implementing Regulation (EU) 2020/1435.
ECHA’s Current Awareness Campaigns
The two campaigns announced by ECHA in January focus on:
- Joint submissions where the lead registrant has changed but the new lead registrant has not yet submitted the complete set of information on behalf of the joint submission.
- Registrations that do not comply with EU-wide harmonised classification under the Classification, Labelling and Packaging Regulation (CLP).
ECHA has indicated that affected registrants will be contacted directly and requested to update their registrations within a set timeline.
Challenges for Lead Registrants
The first campaign may prove particularly challenging for some joint submissions, as the ability to submit the complete set of information relies upon the outgoing lead registrant transferring a robust and complete dataset to the incoming lead registrant – something that is not always achieved in practice.
In many cases, particularly for older dossiers, dataset quality can be questionable and significant investment may be required to bring submissions up to the standard necessary to meet current completeness check requirements.
REACH Compliance Requires Ongoing Oversight
These campaigns again highlight the importance of viewing the REACH Regulation as an ongoing obligation rather than a tick-box exercise. Registrants should understand the status of all joint submissions of which they are members, both to maintain compliance and to anticipate potential future costs. Significant dossier updates can carry equally significant financial implications.
What Triggers a REACH Dossier Update?
Examples include:
- Any change in registrant’s status or identity.
- Any change of composition.
- Any change in tonnage band.
- New identified uses.
- New knowledge of risk of substances to human health or the environment.
- Change in classification and labelling.
Blue Frog Scientific can advise on keeping dossiers as up-to-date as possible, whether you are a member or a lead registrant. Get in touch to speak directly with one of our REACH regulation consultants.
