January 21, 2019 by Cleanncy Hoppie
As the new year begins, it is important to be aware of the changes to the dossier evaluation process that ECHA announced last year, and to take proactive action to keep your REACH dossiers updated.
From January, ECHA will send draft decisions to all non-compliant registrants of a substance, rather than just the lead registrant. Similarly, when ECHA make a decision on a testing proposal, all registrants who rely on the proposed tests to fulfil their information requirements will now be notified of the decision. Previously, members of a joint registration were alerted to dossier evaluation decisions by the lead registrant through substance information exchange fora (SIEFs). As of 1st June 2018, following the final phased REACH registration deadline, SIEFs ceased to exist, but joint registrants are still obliged to submit joint information on their substance.
If you have registered any substances under REACH it is therefore increasingly important that you check your REACH IT account for any communications from ECHA, and that you continue to co-operate with other members of the joint submission in order to keep dossiers updated. All registrants should update their dossiers when new information becomes available. Once a draft decision is received, changes to the tonnage band, uses or the intermediate status of a registration will no longer be considered by ECHA.
ECHA recommend regularly updating your dossiers, paying particular attention to the following areas:
- Changes in production or import volumes (increase or decrease)
- New or obsolete uses
- New or changed measures to ensure the safe use of your substance
- Your transported or on-site isolated intermediate status
- New data on the intrinsic properties of your substance
- Your justification for relying on waivers for the required information, or on adaptations such as category or read-across approaches.
- Updates to contact details both in REACH-IT and in your joint submission.
wca can help you to remain in compliance with the REACH regulation, through support with dossier updates for both lead and co-registrants and by preparing responses to decision letters received from ECHA. For further information please see our REACH webpages, or contact us directly.