Industry Taking Requirements to Update REACH Dossiers Lightly

ECHA director Geert Dancet has criticized companies that do not meet their obligations to update REACH dossiers at all, or that do so inadequately. Such companies, he says, misunderstand Article 22 of REACH. Dancet made his comments in July during the annual meeting of the Committee for Environment, Public Health, and Food Safety (ENVI) of the European Parliament.

Article 22 states that registrants must proactively update their registrations in good time based on pertinent new information and then transmit the new information to the ECHA. Updates are required when any of the following occurs:

  • The status of the manufacturer or importer changes
  • The composition of the substance changes
  • The tonnage range of the substance changes
  • The substance is now being used in ways that Annex VI Section 3.7 discourages
  • Recognition of a substance’s risks leads to modifications of the safety data sheet or the chemical safety report
  • The classification and labeling of the substance changes
  • The content of the chemical safety report or of Annex VI Section 5 changes
  • A registrant’s determination that an experiment according to Annex IX or Annex X is to be performed
  • The accessibility of the information in the registration dossier changes

According to Dancet, companies should update their dossiers every five or ten years and pay the ECHA an appropriate fee.

Dancet’s deputy, Jukka Malm, made similar comments in the last ECHA report. See our report in our posting: Registration Dossiers: ECHA Calls for Regular Updates.

The ECHA undertook two projects between June 2016 and July 2017 to inspect the completeness of dossiers and encourage companies to supply any missing data. Among normal registrants, 35 of the requests were met and two approvals were rescinded because of missing data. More than 40 approvals given to lead registrants were inspected, but only one of them was rescinded. The ECHA reported on the projects in July.

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