Revocation and invalidity of registration decisions

Revocation and invalidity of registration decisions

REACH registrations grant companies the right to manufacture or import substances in the European Economic Area (EEA). However, under certain circumstances, ECHA may revoke or invalidate a registration decision.

Registrants affected by revocations or invalidations are informed that they are no longer allowed to manufacture or import the substance in the EEA. The corresponding national enforcement authorities are also informed.

Revocation of registration decisions

According to the REACH Regulation, ECHA ensures that a registration meets several requirements. A technical completeness check ensures that a registration dossier contains all the information required. A financial completeness check ensures that all the required fees have been paid before the registration decision is issued.

The revocation of a registration decision may be decided by ECHA in the following cases:


Financial completeness

The amount of the registration fee to be paid depends on the company size declared by the registrant. SMEs are eligible for reductions on the registration fee.

If the company size was wrongly declared, leading to an undue reduced registration fee, an invoice for the remaining balance of the applicable registration fee will be issued, as well as an invoice for an administrative charge.

If the company does not pay the invoice for the balance to the applicable registration fee within the set deadline, their registration is financially incomplete. In this case, the previously issued registration decision is revoked, and the registration number becomes no longer valid.


Existence of the legal entity owning the registration

Registrants must be an actual natural or legal persons established in the EEA. In order to meet this condition they must be legally registered according to national law. 

ECHA collaborates with national enforcement authorities to identify companies that are no longer established in the EEA Member State or that are not legally registered anymore (e.g. liquidated company); in these cases, the registration decision be revoked and the registration number becomes no longer valid.

Registrations of companies established in the United Kingdom, except those located in Northern Ireland, became void after the end of the transitional period of the UK’s withdrawal from the EU on 31 December 2020, and their registration decisions were subsequently revoked.

Invalidity of registrations

According to the REACH Regulation, when a registrant informs ECHA that they ceased manufacture and import after they received a draft decision under dossier evaluation or substance evaluation, the registrant will not receive the final evaluation decision requesting further information on the substance and the corresponding registration is no longer valid.

Temporary revocation of registrations of legal entities subject to EU restrictive measures (sanctions)

ECHA complies with individual sanctions established by EU Council Regulations adopted pursuant to Article 215 of the Treaty on the Functioning of the European Union (freezing of economic resources). If a registrant – or, for an only representative, the non-EU manufacturer they represent – is found to be listed under any of those EU Council Regulations, or owned or controlled by a listed person or entity, and no exemption or derogation from these measures applies, their registrations may be temporarily revoked.

If the restrictive measures are later lifted (i.e. the relevant person or entity is de-listed) or any other condition for their application is no longer fulfilled, ECHA will reinstate the registration decisions.