Registration Maintenance
ECHA has issued a number of guidance documents since 2008, aimed at facilitating the implementation of REACH, CLP and the biocides legislation by describing good practices on how to fulfil the obligations. They are developed with the participation of many stakeholders: industry, Member States and NGOs. All guidance documents can be found on http://echa.europa.eu/web/guest/support/guidance
With regard to registration, the following documents were more specifically recommended:
Relevant guidance from a generic list of obligations under REACH and CLP, it contains all potential obligations (e.g. with a link to guidance on how to fulfil these obligations: http://echa.europa.eu/support/guidance-on-reach-and-clp-implementation/identify-your-obligations
All support information from ECHA (Q2-2017, tools, practical guidance) on registration can be found here: https://echa.europa.eu/support
The last registration deadline was in June 2018.
The registration activities therefore became "registration maintenance", i.e. ensure that the submitted dossier remains up to date and state of the art.
In October 2020, the European Commission published in the Official Journal the Implementing Regulation (EU) 2020/1435 to clarify when companies need to update their REACH registration dossiers. The requirement to update ‘without undue delay’ is in most cases specified as three months and, in more complex cases, up to 12 months. Additionally, the Implementing Regulation specifies that "the responsibility to update their registrations requires registrants to monitor and track all relevant information in order to ensure their registrations remain up-to-date at all times. In the case of joint submissions, the responsibility to update the registration is, for information that was jointly submitted, the responsibility of all the registrants". On this purpose, Eurometaux has developed a check-list to facilitate co-registrants to understand their role in the registration updating process.
NEW IN>> Guide for compliance with EU REACH- Article 22
This industry-generated guidance document compiles best practices to facilitate the interpretation of the obligations related to Implementing Regulation 2020/1435 on REACH Dossier Updating, which in turn is intended to provide greater clarity about REACH Article 22 on Registration dossier updates . An important section, authored by Eurometaux is about co-registrant updates within joint submissions: Chapter 12 contains an 11-point check-list indicating the key dossier aspects for co-registrants to review when deciding whether a co-registrant update is required by their company.
Last page update: 27 October 2021