In May 2019, ECHA, with support from the European Commission, announced it will take increased action against REACH dossier non-compliance. This comes as an urgent response to the high numbers of missing or inaccurate data in registration dossiers. Data accuracy is vital to achieve its mission to provide information on the substances within the EU market.
With ECHA increasing dossier checks from 5% to 20% across all registrations, not just lead registrants, it is imperative that chemicals importers review their REACH registration dossier now, to ensure all information is complete, accurate and up-to-date. This is especially pertinent to those who have expanded in the market and may now have new uses to consider adding.
Proper REACH registration provides your access to the European market; without it, you risk lost business and potential ramifications from EU manufacturing and end-user customers.
The ECHA Compliance Check Process
If your dossier is flagged and enters the compliance check process, there is limited opportunity to update your information to ensure compliance during the review.
With tightened data requirements and increased quality control, any data exemptions and their explanations will be under scrutiny and may no longer pass ECHA’s revised standards. In this review process the automated data check system is being replaced by a manual process with human eyes sifting through answers to ensure accuracy and compliance.
ECHA will request any unsatisfactorily answered or missing components of your dossier. If you can provide that information upon request, great. It will be business as usual.
If you still lack the information that you were not prepared to answer years ago in your initial chemical registration, then it is better for your business and your customers’ businesses now if you make moves to resolve that information.
Plan for Compliance Now — Review Your REACH Dossier
As the quality requirements have tightened, we recommend all registrants to review their REACH dossiers to confirm they meet the requirements.
Tetra Tech’s team of regulatory experts is available to help review your REACH dossier and to run it through the set of ECHA requirements. We can also help you resolve any issues that arise, so if you do find your dossier in the ECHA review process, Tetra Tech will be there to help you navigate the waters.
Please contact us to start your REACH dossier assessment.