Clarification on REACH registration update deadlines
Date: 15 December 2020
In October 2020 the European Commission has published the Implementing Regulation (EU) 2020/1435 related to registration updates under REACH. Companies should update their registration dossiers when their substance data, tonnage band or company information changes to keep the registration up-to date at all times.
For such updates, the new implementing regulation sets certain time frames:
A deadline of three months applies for administrative updates (for example change in a registrant’s status or name)
A deadline of three months applies for changes in the substance composition
A deadline of three months applies for new identified uses/ new uses advised against
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 when 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.
If registrants do not update their registrations within the given deadlines, they have failed to update the necessary information ‘without undue delay’. This is where enforcement authorities may step in.
This Regulation enters into force in December 2020.