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ECHA to review completeness of registrations

20 April 2016

A Board of Appeal decision (A-002-2013) has clarified the obligations of registrants of the substances to belong to a joint submission and the role ECHA should take to implement this. The decision allows ECHA to request further information through a completeness check. If the missing information is not provided within the deadline, ECHA have the right to revoke a registration.

The first set of dossiers that ECHA will perform completeness checks on will be the individually submitted charcoal dossiers, and ECHA will ensure they become part of the existing charcoal joint sumission. In addition to this, ECHA will prepare to retroactively check all dossiers that may breach their 'one substance, one submission' principle. This represents Ca. 1.5% of registrants, or 700 dossiers.

If a dossier is found to be incomplete, registrants will be given time to update their dossier with the missing information. This may require discussions on joining the submission for the same substance. If deadlines are met, substances can remain on the market without interruption. However, fail to meet the deadline and the registration will lose its validity, causing the company to lose their European market access!

If you have any concerns about the completeness of your registration dossiers, contact ReFaC now to arrange a REACH Compliance review.

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