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ECHA's screening finds REACH registrations in breach of update obligation


The European Chemicals Agency (ECHA) carried out two campaigns during 2021-2023 to remind companies of their obligation to keep their REACH registrations up to date. As a result, 57 registrations were reported to the national enforcement authorities for further action.

Helsinki, 27 September 2023 – 57 of the 689 screened registrations are still in breach of the update requirements under REACH Article 22 after the campaign. This concerns 50 companies in 11 Member States.

The first campaign focused on 148 registrations of substances of very high concern (SVHC) on the REACH Authorisation List. Registrants or their downstream users can only use these substances if they have a valid authorisation from the European Commission. Uses without an authorisation need to be discontinued – unless they are exempted from the authorisation requirement.

Registrants of these SVHCs were requested to verify if the uses reported in their registrations were up to date and reflected the current uses in their supply chains. As a result, four registrations were brought to the attention of the national enforcement authorities. 30 companies indicated that they had ceased all manufacture and import of the substance.

The second campaign focused on substances that have an EU-wide harmonised classification and labelling under the Classification, Labelling and Packaging Regulation (CLP). The campaign targeted 541 registrations that did not comply with the harmonised classification. After the companies were contacted, 488 of these registrations were updated or the company indicated a cease of manufacture or import. 53 cases were sent to the national enforcement authorities. Industry associations helped raise awareness among their members during the final months of the campaign.


The two targeted campaigns were run to support the Commission’s Implementing Regulation (EU) 2020/1435, which entered into force in December 2020. This regulation clarifies the deadlines for registrants to update their registrations as per REACH Article 22. Companies must at own initiative update their registrations, for example, following an increase in tonnage band, changes in uses or the classification and labelling of the substance.

Press contact: Mikko Väänänen,, +358 40 520 3513