The ECHA REACH committee requires companies to update their registrations on their initiative ‘without undue delay’ If they have chemical data, tonnage band, or company information changes. The meaning of ‘without undue delay’ has been clarified by ECHA with explanations of the initial stage for each deadline in the regulation.

● A deadline of three months applies for administrative updates, such as a change in a registrant’s status or identity.

● A deadline of six, nine, or 12 months applies for more complex updates, for example when the classification and labeling of a substance without a Harmonised classification changes, or there are changes in the chemical safety report or guidance on safe use.

● When there are multiple reasons for updating a registration, only one submission is required, and the longest deadline applies.

● A deadline of three months applies to information that the manufacture or import of a substance has ceased.

ECHA added that these deadlines apply for changes to the substances which was already notified under the Dangerous Substances Directive (NONS) and considered under REACH. Companies are requested to monitoring their systems to identify the changes and should keep records of those changes, so they can show their national enforcement authorities that the necessary updates have been done for all their substances. The updated registration guidance will be published on ECHA’s website during the first half of 2021.



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