Deadlines for REACH dossier updates clarified

The EU Commission has clarified the deadlines for the requirement to update registration dossiers “without undue delay”. The deadlines range from three to 12 months depending on the complexity of the revisions.

In the new Commission Implementing Regulation of 9 October 2020, the European Commission clarifies deadlines for dossier updates as follows:

• A deadline of three months applies for administrative updates

• A deadline of six, nine or 12 months applies for more complex updates, such as changes in the chemical safety report or guidance on safe use

Registrants, who have registered chemicals under the previous NONS regulation (the Dangerous Substances Directive), must also comply with the deadlines as these chemicals are considered registered under REACH.

Note that the responsibility for updating jointly submitted registrations lies with all co-registrants, that is, both the lead registrant and the members of the joint submission.

The implementing regulation enters into force in mid-December 2020.

For more information, please contact:

Anne Rathmann Pedersen
Tel +45 4516 9370