What you need to submit

As a registrant of a substance, you need to compile all the required information in a registration dossier, which has two main components:

  • A technical dossier is always required for all substances subject to the registration obligations
  • A chemical safety report is required if you manufacture or import a substance in quantities of 10 tonnes or more a year.

Your registration dossier has to be prepared using the IUCLID software application. IUCLID implements the harmonised templates developed by the OECD. It is compatible with other chemical legislations around the world.

Once your dossier has been created with IUCLID, it has to be submitted to ECHA through REACH-IT.

 

Technical dossier

If you are a manufacturer or importer, you have to collect all existing available information on the intrinsic properties of a substance as well as on its manufacture, uses and exposure.

The technical dossier contains information about:

  • The identity of the substance
  • Information on the manufacture and use of the substance
  • The classification and labelling of the substance
  • Guidance on its safe use
  • (Robust) study summaries of the information on the intrinsic properties
  • Proposals for further testing, if relevant
  • For substances registered in quantities between 1 and 10 tonnes a year, the technical dossier also contains exposure related information for the substance (main use categories, types of use, significant routes of exposure)

The information you need to submit on the properties of a substance varies according to the tonnage in which the substance is manufactured or imported. The higher the tonnage, the more information that is required.

The information requirements are described in the annexes of REACH. For tonnages below 100 tonnes a year, they are described in Annexes VI, VII and VIII. Under certain circumstances, it may be possible not to perform the test required. This is called an adaptation to the information requirement.

You have to compare the information requirements with the information gathered. You can then identify information gaps and consider how to generate any missing information.

The information gaps can be filled by using different sources of information other than testing on vertebrate animals. You may use a variety of alternative methods such as (Q)SAR and in vitro tests. Grouping of substances and applying read-across are possible adaptations to information requirements. Tests on vertebrate animals should only be performed as a last resort.

Testing proposals

In principle, to fulfil standard information requirements outlined in Annexes VII and VIII, you do not need to submit a proposal to ECHA for performing a test. You simply go ahead with the testing to fill in your information gap.

However, under certain circumstances, you need to submit a testing proposal. This is the case, for example, if the test performed under Annex VII gives an indication of concern. You then need to verify the concern by performing a test meant for substances produced in higher volumes (covered in Annex IX or X).

The proposal must demonstrate that the results of the test will provide information on the properties of the substance which is appropriate to make sure that human health and the environment are protected.

If your proposal for testing involves testing on vertebrate animals, ECHA will publish the name of the substance and the hazard endpoint for which vertebrate animal testing is proposed. Third parties can then submit scientifically valid information and studies that address the relevant substance and hazard endpoint as covered in the testing proposal within 45 days.

Taking into account the information received, ECHA will examine the proposal and draft a decision in which it states whether it accepts or rejects the proposal, or requires modification to the conditions under which the test is carried out.

 

Chemical safety assessment and report

If you manufacture or import a substance at 10 or more tonnes a year, you must conduct a chemical safety assessment to define the conditions of use under which the risks can be controlled. These conditions include operational conditions, such as temperature and risk management measures, for example, the need to use personal protective equipment.

The results of the chemical safety assessment are documented in a chemical safety report (CSR), which you need to submit as part of your registration dossier to ECHA.

The chemical safety assessment has the following steps:

1.  Collection and generation of information on intrinsic properties of the substance

2.  Human health hazard assessment

3.  Physicochemical hazard assessment

4.  Environmental hazard assessment

5.  Persistent, bioaccumulative and toxic (PBT) and very persistent and very bioaccumulative (vPvB) assessment

If, after these steps, you conclude is that your substance is hazardous, the following are also needed:

6.  Exposure assessment

7.  Risk characterisation

You need to repeat these steps by re-assessing the hazard information and revising the conditions of use, the exposure information or the scope of exposure scenarios until you can conclude that the risks are controlled.

If you are a downstream user, you should inform your suppliers of your uses of a substance so that they can include that use in their chemical safety assessments. However, you may also choose to carry out your own chemical safety assessment if your use falls outside the conditions described in the exposure scenario of your supplier, or if the use is advised against by your supplier.

Chesar is a tool developed by ECHA to help you perform your chemical safety assessment and generate your chemical safety report.