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ECHA Announces Changes to Completeness Checks

By Lynn L. Bergeson & Carla N. Hutton on February 8, 2023
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The European Chemicals Agency (ECHA) carries out a completeness check on each incoming registration, as set out in Article 20(2) of the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation. In 2021 and 2022, the European Commission (EC) amended some of the information requirements for registering chemicals under REACH. In its January 23, 2023, press release, ECHA states that, beginning May 1, 2023, it will start checking both new registrations and updates to existing ones against the amended requirements, which will also take effect May 1, 2023, and will apply to both new registrations and updates of existing ones. ECHA states that registrants should prepare for the changes, as registrations submitted before may no longer pass the completeness check.

The new and amended checks concern:

  • Substance identity: Ensuring correct and consistent identification of a substance’s boundary composition and its constituents and additives based on clarifications made to REACH Annex VI; and
  • Standard information requirements based on REACH Annexes VII-XI: Supporting registrants in reporting information for endpoints concerning mutagenicity, degradation, and aquatic toxicity based on REACH Annex VII-XI information requirements. Registrants adding a new weight-of-evidence adaptation will be prompted to provide arguments for the approach in a more structured format.

According to ECHA, in parallel, it has made limited revisions to the completeness check in other areas, such as use information. ECHA notes that the IUCLID validation assistant will also be updated with the amended completeness check rules when the new version of IUCLID is released at the end of April 2023. ECHA encourages registrants to use the validation assistant to check their registrations before submitting them to ECHA.

ECHA held a webinar on February 8, 2023, for stakeholders to learn more about the changes. A recording is available.

Photo of Lynn L. Bergeson Lynn L. Bergeson

President of The Acta Group (Acta®), Ms. Bergeson counsels clients on issues pertaining to chemical hazard, exposure and risk assessment, and risk communication. She has earned an international reputation in the legal and regulatory aspects of conventional and nanoscale chemical regulatory…

President of The Acta Group (Acta®), Ms. Bergeson counsels clients on issues pertaining to chemical hazard, exposure and risk assessment, and risk communication. She has earned an international reputation in the legal and regulatory aspects of conventional and nanoscale chemical regulatory programs under the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the European Union’s Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), and on issues pertinent to nanotechnology and other emerging transformative technologies. Specialties include chemical product approval and regulation under TSCA, FIFRA, and REACH, as well as nanoscale substances and nanomaterials law, policy, and regulation.

Today, Ms. Bergeson works with corporations and a wide range of trade associations on evolving regulatory and policy matters pertinent to products of conventional, biotechnology, biobased chemicals, nanotechnologies, and other emerging technologies particularly with respect to TSCA, FIFRA, Food Quality Protection Act (FQPA), REACH and REACH-like programs, and Occupational Safety and Health Administration (OSHA) matters.

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Photo of Carla N. Hutton Carla N. Hutton

Since 1996, Carla Hutton has monitored, researched, and written about regulatory and legislative issues that may potentially affect Bergeson & Campbell, P.C. (B&C®) clients. She is responsible for creating a number of monthly and quarterly regulatory updates for B&C’s clients, as…

Since 1996, Carla Hutton has monitored, researched, and written about regulatory and legislative issues that may potentially affect Bergeson & Campbell, P.C. (B&C®) clients. She is responsible for creating a number of monthly and quarterly regulatory updates for B&C’s clients, as well as other documents, such as chemical-specific global assessments of regulatory developments and trends. She authors memoranda for B&C clients on regulatory and legislative developments, providing information that is focused, timely and applicable to client initiatives. These tasks have proven invaluable to many clients, keeping them aware and abreast of developing issues so that they can respond in kind and prepare for the future of their business.

Ms. Hutton brings a wealth of experience and judgment to her work in federal, state, and international chemical regulatory and legislative issues, including green chemistry, nanotechnology, the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Toxic Substances Control Act (TSCA), Proposition 65, and the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) program.

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  • Posted in:
    Environmental and Climate
  • Blog:
    REACHblog™
  • Organization:
    The Acta Group

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