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Registration Maintenance

ECHA has issued a number of guidance documents since 2008, aimed at facilitating the implementation of REACH, CLP and the biocides legislation by describing good practices on how to fulfil the obligations. They are developed with the participation of many stakeholders: industry, Member States and NGOs. All guidance documents can be found on http://echa.europa.eu/web/guest/support/guidance

With regard to registration, the ECHA website also proposes specific support here: https://echa.europa.eu/support/registration

The last registration deadline was in June 2018. The registration activities therefore became "registration maintenance", i.e. ensuring that the submitted dossier remains up to date and state of the art.

In October 2020, the European Commission published in the Official Journal the Implementing Regulation (EU) 2020/1435 to clarify when companies need to update their REACH registration dossiers. The requirement to update ‘without undue delay’ is in most cases specified as three months and, in more complex cases, up to 12 months. Additionally, the Implementing Regulation specifies that "the responsibility to update their registrations requires registrants to monitor and track all relevant information in order to ensure their registrations remain up-to-date at all times. In the case of joint submissions, the responsibility to update the registration is, for information that was jointly submitted, the responsibility of all the registrants".

To support this, a checklist was developed by Eurometaux to facilitate co-registrants' understanding of their role in the registration updating process: Checklist for Co-Registrants after lead registrant (LR) dossier Updating

 

Guide for compliance with EU REACH-Article 22 (Version 2025)

This industry-generated guidance document compiles best practices for updating the REACH Dossiers considering the Implementing Regulation 2020/1435

What is new in this 2025 version is: 

  • Consideration of "reasons for update" in IUCLID and the consequences within the Joint Submission.
  • Clarifications on tonnage downgrades, highlighting the need for case-by-case assessments (BoA-001-2023 and BoA-001-2024).
  • A new section addressing dossier updates when co-registrants may be subject to Russia-related sanctions.

To further support registrants: we have prepared a 1-page summary of practical recommendations based on this Guidance. It outlines key triggers, deadlines, and best practices for keeping REACH dossiers up to date in line with Article 22.

 

Last page update: 25 July 2025