How to organize for REACH update

The REACH registration dossier has to reflect the current knowledge on how your substance can be used safely at production sites and by users throughout the supply chain. This means­­­­­­­­ that after you have received registration number, you still have work to do.


  1. Get organised within your company

You are responsible for keeping your REACH registration up to date. The information about your company, the composition of the substance and the uses of your customers, for example, are the parts of your registration that you need to maintain yourself.


You need to have processes, systems and alerts in place in your company, so that you can identify when you have to make REACH registration update. For example, you need to set up a process to receive and analyse feedback from your customers, and follow up the scientific literature concerning your substance.


You must update your dossier, in IUCLID format, for example in the following cases:

  • You change your raw material, production process or supplier, and as a result your substance now contains different (hazardous) impurities or (minor) constituents.

  • You change the import or production volume of your substance.


If your volume increases and moves up to the next tonnage band, there are two possible situations:

  • The required data is already available through the joint registration: Inform your co-registrants (including the lead) which additional studies you need.

  • The data is not available through the joint registration: Submit an inquiry to ECHA.

You have to submit all updates of your registration to ECHA through REACH-IT without undue delay.


Most REACH dossier updates are free of charge. However, there is a fee for a tonnage band upgrade.


2. Get organised with your co-registrants


All co-registrants (lead and member registrants) have a shared responsibility to keep the joint part of the registration up to date. It comprises of information about the physico-chemical, toxicological and eco-toxicological properties of the substance, classification and labelling, and guidance on safe use.


The joint part of the registration has to be updated, in IUCLID format, for example in the following cases:

  • You become aware of new hazardous properties for the substance.

  • A jointly submitted chemical safety report needs to be updated, following the identification of new uses or uses advised against for the substance, for example.

  • The classification and labelling of your substance changes.

  • A company in the joint submission increases their production volume and moves to a higher tonnage band.

All updates to the joint part of the registration have to be submitted by the lead registrant through REACH-IT without undue delay or by the deadline stated in the authority’s decision.


These dossier updates are free of charge, except if you make a request for specific information to be kept confidential.


You need to update the REACH dossier but you don't know how? Our experts can help you! Don't hesitate to contact us (info@chem-consulting.si).


Source: http://echa.europa.eu/


Disclaimer:

Information on this blog is prepared with utmost care, but provider does not assume any responsibility or liability for the correctness, accuracy and up-to-dateness of published content. If you need advice for a specific case, you can contact us.