Under article 22 of the REACH regulation, companies that have submitted their registration dossiers have the requirement to update their dossiers as soon as an update on certain information becomes available. However, the results of the latest REACH reviews show that companies have not fulfilled their duties in updating their registration dossiers or that all the necessary information has not been included. In addition, many companies have also failed their REACH compliance concerning their products safety data sheets.
From April 2020 ECHA will also check that companies’ chemical safety report is complete. Before, the CSR has been outside the scope of the completeness check. In parallel, ECHA will also strengthen computerised completeness checks on use information. It is important to remember that these completeness requirements apply to all registrants where relevant, not just the Lead Registrant.
In general it is always best to update the registration dossiers as soon as new information becomes available. When the authorities or ECHA request updates, there is only a limited time to submit the information. REACH compliance doesn’t mean only having a registration number. Every company should take responsibility of their data and not forget their REACH responsibilities.
Join Our webinar We invite all REACH registrants to join our webinar and learn how to maintain up-to-date their REACH registration dossiers for eventual ECHA and national authority checks.
Speaker: Sini Suomela, Head of OR and Registration practice