ECHA: 80% of Companies Complete REACH Dossier Updates; Non-compliant Cases Referred to Enforcement Authorities

In early 2026, the European Chemicals Agency (ECHA) launched two targeted compliance-check actions concerning REACH registration dossier update obligations. The latest figures show that these actions have achieved significant results: four out of five companies have completed the relevant dossier updates. CIRS Group provides the following guidance on REACH dossier update obligations.

Two actions yield significant results

The first action focused on joint submissions where a complete joint registration dossier had not been established in time after the lead registrant was changed. Currently, 80% of the joint submissions that previously lacked a joint registration dossier have now completed the full data package, while another 8% are in the process of updating.

The second action targeted registration dossiers that did not comply with the harmonised classification requirements under the Classification, Labelling and Packaging Regulation (CLP). Data show that 80% of registrations with such non-compliance have been updated.

Next steps

ECHA stated that the next step will be follow-up with registrants who have not responded to the update requests. Notably, all cases in which the dossier still lacks harmonised classification information have been referred to the national enforcement authorities of Member States. This means companies that have not made timely corrections may face enforcement investigations at Member State level and corresponding legal consequences.

Dossier update obligations

CIRS Group reminds companies that dossier updating is an ongoing obligation; obtaining a registration number does not mean the end of obligations.

1. Two situations requiring updates

Changes in your own situation: Changes in knowledge about the substance or its uses, such as an increase in tonnage band, new uses, changes in substance composition, etc.
Receipt of official requests: Receipt of an ECHA evaluation decision requiring additional information.

2. External changes affecting updates

Information requirements for chemical registration under REACH may change, affecting dossier updates.
Harmonised classification and labelling (CLH) of hazardous substances is updated annually through the European Commission’s “Adaptation to Technical Progress (ATP)” and should be monitored.

Overview of dossier update deadlines

Under Commission Implementing Regulation (EU) 2020/1435, the dossier update deadlines corresponding to different types of changes are as follows:

Change that triggers the need for updating	Deadline to submit the update	Starting point for the deadline
Any change in the status of the registrant, such as being a manufacturer, an importer or a producer of articles, or in their identity, such as their name or address.	3 months	Counted from the day when the specific change takes effect.
Any change in the composition of the substance.	3 months	Counted from the date when the manufacture or import begins with the change in the substance composition.
Changes in the annual or total quantities manufactured or imported by the registrant.	3 months/6 months (in case of testing proposals)	When no new data needs to be generated, you have 3 months to submit an updated dossier. This is to be counted from the date when the higher tonnage band has been reached. If new data needs to be generated and the registration falls under Annexes VII or VIII of REACH you have 3 months to initiate negotiations with a test lab to generate the missing data. If the information requirements fall under Annexes IX or X of REACH, you have 6 months to update the registration to include the testing proposals for the missing data counted from the date when you identify the need to perform one or more of the tests listed in those annexes.
New identified uses and new uses advised against for which the substance is manufactured or imported.	3 months	For a new identified use, it is counted from the date when you receive all the information needed to carry out the risk assessment. For a new use advised against, it is counted from the date when the information on the risks associated with that use is available to you.
New knowledge of the risks of the substance to human health or the environment of which the registrant may reasonably be expected to have become aware which leads to changes in the safety data sheet (SDS) or the chemical safety report (CSR).	6 months	Counted from the date when you become aware or may reasonably be expected to have become aware of the new knowledge in question.
Any change in the classification and labelling of the substance.	6 months (for self-classification) In case of addition, modification or deletion of the harmonised classification and labelling the update has to be performed by no later than the date as of which the change is to apply.	In case of a new or modified self-classification the deadline is counted from the date when the decision to change the classification and labelling of the substance is taken.
Any update or amendment of the CSR or the Guidance on safe use.	12 months	Counted from the date when the need to update or amend the CSR or the Guidance on safe use is identified.
The registrant identifies the need to perform a test listed in Annex IX or Annex X, in which cases a testing proposal must be submitted.	6 months/12 months	6 months counted from the date when the registrant identifies the need to perform one or more of the tests listed in Annex IX or of X of REACH. If the testing proposal developed addresses a group of substances, the dossier must be submitted to ECHA by no later than 12 months after the date when the registrant or registrants identify the need to perform one or more tests listed in Annex IX or Annex X or REACH.
Any change in the access granted to information in the registration.	3 months	Counted from the date when the change occurred.

Further examples that require an update (e.g. cases when the update require further testing, updates as a consequence of an update on the Annexes of REACH, updates within a joint submission) and explanation on how to calculate the deadline when multiple updates are required are explained in the ‘Guidance on Registration’.

What CIRS Can Do for You

CIRS Group is a leading provider of comprehensive regulatory compliance services and solutions for chemicals, cosmetics, food and food-related products, agrochemicals, and medical devices. Its chemical team consists of experts with extensive knowledge in chemistry, toxicology, environmental science, and related fields. They are well-versed in various international regulations, including but not limited to EU REACH, CLP, GHS, TSCA, and K-REACH. Our chemical compliance services in the EU cover:

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If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further information

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