REACH registration dossiers – how to ensure compliance

The majority of REACH registration dossiers checked contain incorrect data or data gaps. We tell you how you can avoid common mistakes and even save costs.

The latest reports from CEFIC, the European Chemical Industry Council, and ECHA, the European Chemicals Agency, show that most registration dossiers are not legally compliant. ECHA and CEFIC therefore want to check dossiers more intensively in future to ensure that they comply with the requirements of the REACH Regulation.

The onus is on manufacturers and importers

Implementing Regulation 2020/1435 has been in force since the end of 2020 and specifies in which cases and by when registration dossiers must be updated. As a manufacturer and/or importer, you are therefore obliged to update the registration dossier if there are changes, for example

• regarding the tonnage band, company size, composition or use of a substance.
• due to new information requirements under the REACH Regulation. For example, the EU Commission amended Annexes VI to X of the REACH Regulation with Regulation 2022/477, which has been in force since October 14, 2022.
• in the course of updating the harmonized classification and labelling of hazardous substances
• due to new formal requirements for data entry in the IUCLID software application.

Why updating is worthwhile

The examples of material usage and tonnage band illustrate how you can save costs in concrete terms.

• The higher the tonnage band, the more extensive the data requirements and the associated costs. If the quantity of material produced or imported is reduced, you should adjust the tonnage band in the dossier to save costs.
• Also make sure that you only specify the actual use in the supply chain in the dossier. As you have to document and evaluate the use based on data, you should leave out additionally reported uses in order to keep costs as low as possible.

Everything in view?

As some things get lost in the hectic day-to-day business, we keep you up to date with our services. This is important because

• on the one hand, the ECHA wants to tighten up its inspections and you should avoid fines as a result of legal infringements at all costs.
• on the other hand, the situation with regard to the pending REACH revision remains unclear. Further adjustments to the data requirements - keyword polymer registration obligation - are to be expected in any case.

Who we are

KFT Chemieservice GmbH, an Infraserv Höchst Group company, is one of Germany’s leading chemical compliance service providers. We ensure that companies comply fully with all the requirements imposed by chemical laws.

What we do for you

• Record all substance information using the IUCLID (International Uniform Chemical Information Database) software application.
• Preparation of the Chemical Safety Report (CSR) using the ECHA tool CHESAR (Chemical Safety Assessment and Reporting).
• Documentation of the exposure scenarios that are added to the safety data sheet.
  Updating of registration dossiers.
• Complete management, including sending the registration dossier to the ECHA.
• Assuming the role of Only Representative under REACH, Article 8.
• Carrying out any new studies together with our partner laboratory.

The best thing to do is to contact us right away.