Updating Registration Dossiers: EU Sets Deadlines

EU member states have agreed upon deadlines for the updating of registration dossiers and approved a draft. The corresponding implementing regulation should be published this year.

Article 22, Section 1, Letters a-i of REACH define the cases in which registration dossiers must be updated. Depending on the effort involved for an update, the legislation grants deadlines of 3, 6, and 12 months.

For example, a three-month deadline applies when the status and/or identity of the registrant changes. It also applies when the composition of the chemical or the tonnage band is different or if new usages result that are advised against. However, the deadline does not apply when the amount produced or imported is lessened. Such a change does not cause any hazard to health or the environment.

A registrant has six months to update a registration when a dossier must reflect the latest developments that arise from new knowledge about the risks to human health and/or the environment or when the classification and labeling of the chemical has changed.

A 12-month deadline applies when the chemical safety report has been changed or supplemented or when an experiment is to be performed according to Annex IX or Annex X.

The legislation grants registrants an additional grace period because the regulation takes effect 60 days after its publication, rather than the usual 20.

Notes on how to update are provided by the ECHA.

In the past, associations such as Eurometaux, the European Non-Ferrous Metals Association, and the European Chemical Industry Council, Cefic, have criticized the deadlines as too short. See our blog entry, REACH Dossier Updates: Associations Urge Lengthening of Deadlines in Proposed Legislation.

Do you need help with registering a substance? Please contact us at reach@kft.de

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