ECHA: Deadlines for updating registration dossiers clarified

The European Commission has clarified the meaning of "without undue delay" in an implementing regulation, which has now received a favorable vote from all Member States.

Companies are responsible for updating their records with new relevant information, on their own initiative, without undue delay.

The deadlines set for the various types of updates will become applicable after the publication of the implementing regulation, expected by the end of the year.

ECHA is preparing further information for registrants, including an update of the guidance on registration.

Timing to update the registration dossier:

  • Changes in the legal status or identity of the registrant within 3 months
  • Changes in the composition of the substance within 3 months
  • Changes in the tonnage band within 3 months
  • New uses identified and new uses advised against within 3 months
  • New information on risks to human health and / or the environment within 6 months
  • Changes in the classification and labeling of the registered substance within 6 months
  • Updates or changes to the chemical safety report or guidance for safe use within 12 months
  • Testing proposals before carrying out one of the tests listed in Annex IX or X within 12 months
  • Changes regarding the access allowed to information in the registration within 3 months
  • Updates involving additional trials within 3 months
  • Other updates combined within 12 months
  • Common broadcast updates:
    • within 3 months, in the case of a case that provides for an update following a circumstance referred to in Article 22 (1), letters a) to f) or i)within 9 months, in the case of an update or modification of the
    • chemical safety report or guidance on safe use
    • within 9 months, in the event that one of the circumstances referred to in Article 22, paragraph 1, letters a) to f) or i), of Regulation (EC) no. 1907/2006, also entails the need to update or modify an existing chemical safety report or guidelines on safe use
  • Updates following an amendment to the annexes of Regulation (EC) No. 1907/2006, in accordance with article 131 of this regulation, the registration is updated at the latest on the date from which this amendment applies, unless otherwise specified in this amendment.


This Regulation shall enter into force on the sixtieth day following its publication in the Official Journal of the European Union.

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