REACH 2018’s cheery blue ladder of steps to compliance starts with Step 1, Know Your Portfolio, and ends with Step 7, Keep Your Registration Up to Date.But that REACH 2018 Step 7, though it may look like it’s the same size as the others, is quite different. Once you complete your registration, Step 7 — keeping it up to date — lasts forever.
What exactly is involved in keeping your registration up to date?
It starts with your registration number.
“Registration under REACH is not just a one time exercise,” ECHA explains, “and your legal obligations do not end after you receive a registration number.” Your registration can be examined at any time. Random examinations of registrations are possible, but at this point most additional examinations are “concern based” — that is, they are in response to concerns. Concerns are likely to be a question of missing information. For the first group of registrations, those from 2013, concerns were most often related to prenatal developmental toxicity, aquatic toxicity, uncertainties about substance identification, and
But since the REACH process is a lengthy one, spanning years rather than weeks, missing information can refer to changes, as well as to errors and omissions in the original dossier.
ECHA recommends being proactive about keeping your registration current and up to date.
This means keeping track of changes and updating your dossier as they arise — not after they’ve caused concern on ECHA’s part.
Here are some of the events that could require you to update your dossier:
- New information about the substance
- New testing and research
- Changes in the amount of the substance in use by your company
- New use cases in your supply chain
- Other new information from your supply chain
- New members joining your registration
Keeping these points up to date will reduce the chances of your dossier requiring additional examination.
Watch for ECHA reports
ECHA will be posting annual evaluation reports. You are expected to keep track of these and respond to them as needed. This is in addition to the practice of keeping your dossier up to date in response to new information or changes in your circumstances.
ECHA points out that attention to Step 7 — the step that keeps on going for the foreseeable future — can keep you from having to move back to earlier steps. A dossier that is not kept current may require refiling.
Use digital tools for keeping your dossier up to date, keeping track of your data, and maintaining the collaborative relationships you need throughout the process. EUPHOR is the tool we recommend. It’ll keep you on track for REACH and for all your chemical regulation compliance needs.