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Echa report calls for ‘mandatory periodic’ deadlines on REACH dossier updates

New regulatory measures are needed to ensure that companies update their REACH registration dossiers at fixed regular intervals, for example, every three years, according to a report commissioned by Echa.

Companies lack incentives to update, which is a mandatory requirement under Article 22 of REACH, and there is a perception that “no additional work is needed” after registration, the report says.

The report is based on a survey Echa undertook in April and subsequent stakeholder interviews. It recommends mandatory periodic updates of dossiers with clear evidence on continued validity.

If new data became available sooner than three years, an update would be triggered immediately, it says. Otherwise, the registrant would be required to confirm that the data remains correct and up to date.

The report’s recommendation would be best achieved through a “clarification or update” of Article 22, which might be feasibly done through an implementing Regulation.

While Article 22 places a mandatory requirement on registrants to update their dossiers “without undue delay” whenever there is a material change or new information comes to light, it is based on voluntary action. The vast majority of updates are currently triggered by Echa’s own regulatory activities.

In July, Echa head Geert Dancet said a revision every five or ten years should be “normal”.

Many companies blame ‘REACH fatigue’ –  a Chemical Watch survey of top manufacturers in July found that this is put on the back burner as the May 2018 registration deadline takes priority.

And in Echa’s survey, 68% of respondents said they had no system in place to help monitor whether new data is available to update a dossier.

The report, which is addressed to Echa, trade associations and policy makers, proposes four steps:

  • a clear definition of what needs to be updated. This should be targeted to maximise the benefits and limit burden on registrants;
  • a clear definition of who is responsible for the updates – clarifying the roles of the lead and co-registrants;
  • an improved understanding of why updates are important – that they have an impact on protecting the human health and the environment; and
  • an implementing Act to clarify the update requirement of Article 22 of REACH, including clear circumstances and fixed intervals when dossiers need to be updated.