Failures and rejections

If your registration dossier fails the technical completeness check during the first submission, ECHA sends a message to your REACH-IT Tasks box outlining the elements that were found to be missing or incomplete and which need to be amended for your submission to be complete.

You are given a deadline of four months during which you have one chance to amend the incomplete information.

As set out in REACH Article 20(2), if you fail to resubmit your dossier by the technical completeness check deadline or if the second submission is incomplete, your submission will be rejected. ECHA will not refund or otherwise credit any fees paid before the rejection.

Rejection process

After the second failed submission, it takes approximately six weeks to finalise the rejection process. While this process is ongoing, you cannot make new submissions in REACH-IT for the same substance.

When the rejection process is completed, you will receive a decision in your REACH-IT Tasks box. You will also find the related decision letter from the ‘Key documents’ section of the submission page. The decision letter will explain why your registration or notification is rejected.

Consequences of a rejection

You may only start to manufacture or import the substance or to produce or import an article once you have a complete registration and ECHA has issued a registration number to you.

If you already have a complete registration, the rejection of a registration update means that you keep the existing registration number. However, any new information that you had included in the update will not be accepted into ECHA’s database and will not be available for any subsequent regulatory processes.

If your dossier included an increase or change in tonnage band, then you may not manufacture or import the substance, or produce or import an article containing it, above the tonnage band that is currently validly registered until you have submitted a new dossier, which ECHA has confirmed as complete.

If the update of the registration dossier was submitted to include nanoforms of the substance then the rejection means that, even though you maintain your existing registration number for the non-nanoforms of the substance, the registration does not cover the manufacture or import of the nanoforms of the substance.

Registrants that manufacture or import nanoforms of the substance after 1 January 2020 without a registration that covers these nanoforms are in breach of REACH, which may trigger enforcement measures.

Rejection with invoice pending

If a registration dossier that is rejected is associated with an invoice, ECHA will send the rejection decision only after the payment is confirmed as having been received, or after the extended due date of the invoice has passed without payment. While this process is ongoing, you cannot make new submissions in REACH-IT for the same substance.