Regulation (EU) 2020/1435 on the duties placed on registrants to update their registrations under Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)

Jurisdiction: GB

Amends: Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), as amended

Mini Summary

Regulation (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) imposes requirements on manufacturers and importers of chemicals and restricts the use of certain high risk chemicals.



The REACH Regulation requires registrants (i.e. those who have registered chemicals under REACH) to update their registrations with any relevant new information. However, no deadlines are provided within which updates must be submitted.  Regulation (EU) 2020/1435 is an implementing Regulation which supplements REACH by setting out deadlines for updating of registrations. Where any of the following changes in circumstances apply, the registrations should be updated within the time frames summarised below:

  1. Registrant’s identity: within 3 months of the change.
  2. Composition of the substance registered: within 3 months of manufacture or import of the changed substance.
  3. Tonnage band: where the quantity manufactured or imported changes, taking the registration into a higher tonnage band, within 3 months of the change (see Article 3 for additional detail).
  4. Cessation of manufacture or import: within 3 months.
  5. Identified new uses of the substance: within 3 months.
  6. Advice against identified use: where new advice is identified against a known use, within 3 months.
  7. New knowledge of risks to human health and/or the environment: within 3 months of the knowledge being identified.
  8. Classification and labelling under ‘CLP’ (Regulation (EC) No. 1272/2008 on classification, labelling and packaging of substances and mixtures): a change in classification or labelling of a substance due to it being in some way re-assessed should be submitted within 6 months. A change to the hazard classification or labelling categories of CLP (i.e. where the CLP Regulation itself is changed) which affects the substance, must be notified by no later than when the change takes effect.
  9. Chemical safety report/ guidance in safe use: within 12 months of a change in either of these.
  10. New testing required under Annexes IX and X: within 6 months of the registrant identifying that new testing is required for a substance, or 12 months if the testing is identified as necessary as part of a testing strategy for a group of substances.
  11. Change in access granted: within 3 months of the change.
  12. New testing required in relation to 1-6 & 8 above: if any of 1-6 & 8 above leads to a requirement to carry out further testing, the deadline for submission of the update is changed to 3 months from the receipt of the test report.
  13. Combined updates: where any of the above circumstances applies and this also triggers the need to update or amend a chemical safety report or the guidance on safe use, the combined update should be submitted within 12 months from the date when the final test reports needed for the update have been received.
  14. Joint submissions: where an update by a member of a joint submission is dependent on a lead registrant making a prior update, the deadline for the member to make the update is:
    • 3 months if it relates to any of 1–8 or 11 above;
    • 9 months if it relates to 9 or 12.

The deadline is from when the HSE informs the lead registrant that their update registration is complete.

Updates of Annexes to REACH
Where any of the Annexes to REACH is amended, resulting in a change of information required to be submitted in support of a registration, the registration must be updated by the date from which that amendment to the Annex applies.

Process for updating registrations
Registrations should be updated through the ECHA. Information for registrants can be found via the ECHA website.


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