You need to have processes, systems, and alerts in place in your company that allow you to identify when you must make changes to your registration. For example, it is recommended that you set up a process to receive and analyse feedback from your customers and follow up the scientific literature concerning your substance. 

You must update your registration dossier, for example in the following cases:

• You change your raw material, production process or supplier, and as a result your substance now contains different (hazardous) impurities or (minor) constituents.
• You change the import or production volume of your substance. If the  volume increases or decreases above or below the tonnage band threshold for which you have registered your substance, this must be reported in your dossier.
  • If the volume increases and moves up to the next tonnage band you must submit an inquiry to ECHA in order to comply with Article 12 (2), referred to as ‘Inquiry Type 4’ in IUCLID. In the inquiry dossier you need to indicate what information you need to satisfy the information requirements in the higher tonnage band. From ECHA’s response on the availability of this information you can discuss with your co-registrants if the data is already available in the joint submission and how to get access to it, for example by buying the relevant letter of access.
  • Not making an inquiry may be regarded by the enforcement authorities as a breach of Article 26 of REACH.
  • If not all information is available to satisfy the information requirements of your registration, you need to consider how to fill in the data gaps. You can find more information on the strategy for gathering your data on phase 4 ‘What information you need’ of the Registration phases.
• You learn of new uses from your customers. In such a case, you may also need to update your CSR.
• You need to update the information related to the properties of your substance which you have submitted separately (opted out) in the joint submission.
• Your supplier reformulates a mixture that you are importing. If a substance is not included anymore in the mixture, then you may need to notify a cease of import of that substance. 
• You become aware of new information on the properties of your substance that needs to be brought to the attention of your co-registrants. You need to agree on how to update the jointly submitted information of the registration.

You can claim confidentiality on the new information in your dossier during the update of your registration, if it concerns information not previously published by ECHA.