Study finds companies lack incentives for updating their REACH registrations

ECHA/NI/17/27

An external report on dossier updates suggests that more clarity is needed on how the registration process works, what needs to be updated and by whom in order for more companies to submit new information on the safe use of their chemicals.

Helsinki, 4 September 2017 – A report, commissioned by ECHA, examines the challenges and incentives for updating REACH and CLP dossiers and identifies best practice that could help companies improve their data. As the main issues affecting companies responsible for updating their information, it mentions the perception that registration is the end of the process and that no additional work is needed afterwards; obscurity of what needs to be updated, when and by whom; and limited resources, especially for SMEs.

The report proposes improvements structured around four steps:

1. A clear definition of what needs to be updated.
2. A clear definition of who is responsible for the updates – clarifying the roles of the lead and co-registrants.
3. An improved understanding of why updates are important – that they have an impact on protecting the human health and the environment.
4. 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.

The recommended actions are addressed to ECHA, the trade associations and the policy makers. The report has been sent to the European Commission for their consideration under the REACH Review expected to be finalised by the end of the year.

Background

The REACH and CLP regulations require companies to update their information whenever new information is available. Article 22 of REACH specifies a number of “further duties of registrants”. These can be divided into those that registrants are expected to do spontaneously under their own initiative and those required by ECHA during the evaluation process. Around 64 % of the registration dossiers submitted to ECHA since 2008 have never been updated.