At the CARACAL meeting held in Brussels at the beginning of July, the members presented a draft implementing regulation for Article 22 of REACH. The Article regulates the updates of registration dossiers. It requires registrants to update their registration promptly and at their own initiative and to notify the ECHA when they have new knowledge about the chemical. Such cases would include changes in composition, a reevaluation of the risks that the chemical poses, and so on. Article 1, points a–i of REACH describe the concrete cases in which a dossier must be updated.
In the past, regular reviews have shown that many dossiers are obsolete and often incorrect. Individual EU member states and industry associations have therefore long argued for an implementing regulation that states concrete requirements for mandatory updating. For example, they claim that the term “promptly” leaves too much room for interpretation.
At their meeting in Brussels, participants gave registrants concrete deadlines for updates. The deadlines differ on a case-by-case basis (a change or status or identity, chemical composition, quantity, risks, and so on) and range from one to six months. An additional point concerns the update of a chemical safety assessment and a chemical safety report. If a change requires both to be updated, the registrant must submit only one combined update within six months.
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