The European Commission (EC) has provided clarification on the deadlines for updating their REACH registration dossiers. The requirement to update the dossiers ‘without undue delay’ is specified as three (3) months in most cases and up to twelve (12) months in complex cases.

According to the REACH regulation, if there is any change in the chemical data, company information or tonnage band, companies must update their REACH registrations ‘without undue delay.’ The meaning of ‘without undue delay’ has been clarified with explanations of the starting points for each deadline in the published implementing regulation.

• A three (3) months deadline applies for administrative updates. For example, change in the registrant’s status/identity.
• A six (6), nine or twelve (12) months deadline applies for complex updates. For example, change in the classification and labeling of a substance without harmonized classification changes, changes in the chemical safety report/guidance on safe use.
• The longest deadline applies and only one submission is required if there are multiple reasons for updating a registration.
• A three (3) months deadline applies to the information about the ceased manufacture or import substance.

The deadlines also apply for changes to previously notified substances under the Dangerous Substances Directive (NONS) registered under REACH.

Companies must ensure that they have monitoring systems in place, which allow them to quickly identify the changes that require them to update their registrations. The records of these changes must be kept, to show the national enforcement authorities that the required updates have been done for all the substances.

As the implementing regulation is expected to come into effect from Dec 11, 2020, companies must update their EU REACH dossiers accordingly and adapt to the new timelines. Stay informed. Stay Compliant.