EC Clarifies Deadline Requirements for Companies Updating Registration Dossiers Under REACH

• October 29, 2020

The European Commission (EC) recently released a draft regulation designed to clarify deadline requirements for the updating of registration dossiers. In this blog post, we take a closer look at this deadline information and how it applies in different circumstances.

Deadline Clarification

A key REACH requirement stipulates that businesses need to update their registrations when the information on the chemicals they use changes. It further stipulates that this be done "without undue delay". Given the inherent potential ambiguity underlying this language, the EC recently sought to clarify it via more specific deadline information.

• For updates that are largely administrative (e.g., status, name, or address changes), there is a three-month deadline for registration updating and submission.
• For instances in which information becomes available regarding any new uses, a three-month deadline for registration updating and submission applies.
• For situations where new information becomes available regarding ways in which the chemical should not be used, a three-month deadline for registration updating and submission applies.
• For instances in which a business stops manufacturing a given chemical, there is a three-month deadline for registration updating and submission.
• For updates that are more complex in nature, deadlines of six, nine, or twelve months may apply. This depends on a variety of factors.
• For situations in which several justifications may exist for conducting an update, the longest deadline for a single registration submission applies.

Failure to Comply

Under current requirements, businesses must be vigilant to make sure that their registrations are updated properly and by their given deadlines. To ensure that businesses are complying, corresponding authorities in the EC may at any time request information from them to verify deadline adherence.

For Access to Additional Vital Information

Maintaining current registration dossier information is a critically important requirement for businesses. This is also a key component of a comprehensive approach to allow the full benefits of REACH to be realized. More information on the EC’s clarification efforts can be found by reviewing their recent draft regulation.

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