Keep your registration up-to-date
A registration dossier has to reflect the most up-to-date knowledge on how a substance can be used safely. Therefore, you have to review it on a regular basis and update it as new information becomes available. This is a legal obligation for all registrants, so it is recommended to maintain the cooperation platform with your co-registrants.
Over time, you may learn more about the composition, properties and uses of your substance and the measures required for effective risk management. You must also report any significant changes in the production process and manufacturing or import volumes, as these may result in changes in exposure to the substance that need to be taken into account. You also need to keep your company information up to date.
New information may also become available through actors in your supply chain or new co-registrants joining the joint submission. It is good to bear in mind that the data-sharing obligations apply to all members – existing and new – of a joint submission.
Being proactive is not only good practice, but also a legal requirement. It is your responsibility to keep your registration up to date and compliant with the information requirements for your tonnage band – even after you have received your registration number, and even if ECHA does not request an update.
ECHA checks registrations - Member States evaluate substances
Authorities will use the information in the registration dossiers as the basis for further regulatory work. This information needs to be up to date, as this helps ensure that your substance is not prioritised for further work based on outdated or wrong information.
ECHA examines the registrations to verify that the information in them is compliant with the legal requirements. The selection for compliance check is either random or concern-based. ECHA publishes recommendations based on the most common shortcomings observed when evaluating registrations – avoid having these same issues in your own registration by following the Agency’s recommendations.
The responsibility for compliance lies with you – it is your responsibility to check and keep up with all the legal obligations that apply to your substance, such as any updated or new harmonised classification and labelling rules.
Member States, in turn, use the registrations to scrutinise substances that may be of concern for human health or the environment and may propose further regulatory actions as necessary.
If you are the lead registrant, you will have the obligation to update the joint part of the registration dossier. However, all affected registrants are responsible – and must share costs – for remedying the situation if an incompliance is found or further information needs to be generated.
- Keep your registration up to date, 6 November 2018
- Special e-News, 6 November 2018
- More information on dossier evaluation processes available, 18 October 2018
- Data on chemicals needs to be improved, 17 October 2018
- ECHA increases visibility of authority activities, 15 October 2018
- Member registrants will start receiving dossier evaluation decisions in 2019, 26 September 2018
- Information on chemicals still has to improve, 28 February 2018
- Study finds companies lack incentives for updating their REACH registrations, 4 September 2017
- Important safety information on chemicals still missing, 27 February 2017
- 2018 – the end of the beginning on chemicals, ECHA Newsletter 2/2017