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Deadlines for updating registration dossiers clarified


The European Commission has clarified when companies need to update their REACH registration dossiers. The requirement to update ‘without undue delay’ is in most cases specified as three months and, in more complex cases, up to 12 months.

Helsinki, 12 October 2020 – The REACH Regulation requires companies to update their registrations on their own initiative ‘without undue delay’ when their chemicals data, tonnage band or company information changes.

The meaning of ‘without undue delay’ has been clarified together with explanations of the starting points for each deadline in the implementing regulation published today.

  • A deadline of three months applies for administrative updates, such as a change in a registrant’s status or identity.
  • A deadline of six, nine or 12 months applies for more complex updates, for example when the classification and labelling of a substance without a harmonised classification changes, or there are changes in the chemical safety report or guidance on safe use.
  • When there are multiple reasons for updating a registration, only one submission is required and the longest deadline applies.
  • A deadline of three months applies to inform that the manufacture or import of a substance has ceased.

These deadlines also apply for changes to substances previously notified under the Dangerous Substances Directive (NONS), which are considered registered under REACH.

Companies are advised to ensure that they have monitoring systems in place that allow them to swiftly identify the changes that require them to update their registrations. They should also keep records of these changes, so they can show their national enforcement authorities that the necessary updates have been done for all their substances.

Keeping the jointly submitted part of the registration up-to-date is the joint responsibility of all co-registrants (lead and members). Registrants need to ensure that they have a collaboration and cost-sharing agreement in place for this activity.

The implementing regulation enters into force in 60 days from today, so companies can adjust to the new timelines.

Further support is available on ECHA’s website and in the update of the registration guidance, which will be published during the first half of 2021. Companies can also get general advice on transitioning to the ECHA Cloud Services and help with migrating their datasets to the latest version of IUCLID through ECHA’s Helpdesk.


Under the REACH Regulation, companies are responsible for collecting information on the properties and uses of the substances they manufacture or import above one tonne a year. They also have to assess the hazards and potential risks presented by the substance.

This information is communicated to ECHA through a registration dossier containing the hazard information and, where relevant, an assessment of the risks that the use of the substance may pose and how these risks should be controlled.

Registration is based on the ‘one substance, one registration’ principle. This means that manufacturers and importers of the same substance have to submit their registration jointly.