According to the latest regulatory guidance from the European Chemicals Agency (ECHA), companies in the chemical industry must treat REACH registration dossiers as "dynamic documents" and continue to fulfill ongoing update obligations even after obtaining registration numbers.
Under the regulations, companies must update their registration dossiers in the following scenarios:
- Changes in substance information or usage information, including tonnage band increases, development of new uses, changes in composition, etc.;
- Receipt of an ECHA evaluation decision requiring supplementary information submission.
Other situations necessitating dossier updates include:
- Revisions to regulatory information requirements or updates to the harmonized classification and labeling of hazardous substances (CLP). Notably, the European Commission revises the CLP annually through the Adaptation to Technical Progress (ATP) procedure.
ECHA may soon initiate IT screening campaigns to identify registration content requiring improvement through targeted activities. Therefore, ECHA reminds registrants to update their dossiers and emphasizes that "maintaining the timeliness of data remains the fundamental responsibility of the registrant."
CIRS Group reminds companies to review the latest ATP regulatory developments every six months, promptly integrate significant research findings (such as new toxicological discoveries or changes in exposure scenarios) into their registration dossiers, and ensure information is communicated along the supply chain so that downstream users receive safety use guidelines consistent with the registration dossiers.
For REACH registration compliance guidelines, please refer to:
https://www.chemradar.com/en/news/detail/ecwupomh962o
