ROHS Compliance

Companies in the chemical industry must approach REACH registration dossiers as "dynamic documents" and continue to complete continuous update responsibilities even after acquiring registration numbers, according the most recent regulatory guidelines from the European Chemicals Agency (ECHA).

In the following situations, businesses are required by law to amend their registration dossiers:

1. Modifications to substance or usage information, such as increases in the tonnage band, the creation of new uses, compositional modifications, etc.;

2. Receiving an ECHA evaluation decision that calls for the submission of more information.

Additional circumstances that call for dossier changes include:

Revisions to regulatory information requirements or revisions to the harmonized categorization and labeling of hazardous chemicals (CLP). Notably, the European Commission uses the Adaptation to Technical Progress (ATP) mechanism to update the CLP every year.

In order to find registration content that needs to be improved through focused efforts, ECHA may shortly launch IT screening campaigns. As a result, ECHA highlights that "maintaining the timeliness of data remains the fundamental responsibility of the registrant" and advises registrants to update their dossiers.