ECHA REACH En-Force-7 Project: 15% of Registration Dossiers Not Legally Compliant

In December 2020, the ECHA Enforcement Forum published the closing report of the REACH En-Force 7 (REF-7) project. As part of the project, national authorities and customs agencies inspected a total of 813 companies in 28 countries. The inspectors found that 180 of the 1,420 chemicals examined are not  registered according to the guidelines found in REACH. Some 77 chemicals had no registration at all.  

At least one of the following obligations were not met in the contested dossiers: 

• The chemical is not registered, or the dossier is not up to date.  
• Intermediates are not handled according to strictly controlled conditions.  
• The current amount is not specified.  
• The only representative does not meet requirements. 

In their investigation, the inspectors concentrated on examining the dossiers of chemicals that were  
registered after the last deadline in May 2018. They paid particular attention to chemicals registered as  
intermediates and focused on the following questions:  

• Does the chemical registered correspond to the definition of an intermediate? 
• Are the intermediates manufactured and/or used in strictly controlled conditions? 

Companies can benefit from reduced information requirements only when the answers are affirmative.  
Otherwise, the chemicals must be registered in full. More information is available here.  

The authorities punished violations according to their severity, a process that is still ongoing. By  
mid-December, they issued 17 fines and submitted complaints to public prosecutors in 26 cases.  

We can submit registrations according to Article 10 and Article 18 (REACH), and we handle the duties of a only representative according to Article 8. Please contact us at reach@kft.de.