Q&A info

Yes. A request for a change of a substance identifier can be made by submitting a “Substance identity adaptation service web form”, which is accessible via ECHA’s website, at the following link: https://comments.echa.europa.eu/comments_cms/SubstanceIdentityAdaptation.aspx

It is technically not possible for registrants to change the substance identifier (EC or list number and name) of their registration dossier without requesting the change of identifiers service.

The request is normally made by the lead registrant, on behalf of the members of a joint submission. Member or individual registrants can also make the request. The request must include documentary evidence that all members of the joint submission agree with the changes specified in the request that affect their registration dossier.

Registrants will need to submit collectively the information included in the ‘Joint Submission Plan’ template, which is available on ECHA’s website: https://comments.echa.europa.eu/comments_cms/SubstanceIdentityAdaptation.aspx.

Once you submitted the request to change the substance identifier, the following steps take place:

1. You receive an automatic email confirmation that includes the unique reference number of your request.
2. ECHA assesses if the service can be provided based on the provided information. ECHA contacts you if the request is incomplete or cannot be provided.
3. If ECHA considers that the service can be provided, it issues a service charge to each applicable registrant.
4. After the registrants have paid the service charges, ECHA carries out the changes in REACH-IT.
5. ECHA requests the registrants to update their registration dossiers using the new substance identifier and provides instructions on how to submit the dossier update.
6. You and the applicable registrants submit dossier updates using the new substance identifier.

For further information about the service to change the substance identifier in a registration, please see “How to change your substance identifier” page on ECHA’s website, at the following link: https://echa.europa.eu/support/how-to-improve-your-dossier/how-to-change-your-substance-identifier.

The minimum charge is €300 (€600 for requests received from 1 November 2021) for each registrant requiring the correction of a substance identifier. More information is available on ECHA’s website: https://echa.europa.eu/support/how-to-improve-your-dossier/how-to-change-your-substance-identifier.

The REACH Regulation does not impose any timeframe on ECHA for processing a change of substance identifier request. ECHA aims to assess whether the service can be provided within 1 month. The whole change of substance identifier process normally takes between 3-6 months, if all required information has been provided, the request can be granted, the invoices are paid in a timely fashion, and the dossiers are successfully updated without delay by the registrants.