As of 2019, ECHA will send its dossier evaluation decisions to all non-compliant registrants of a substance. Other changes will be implemented at the same time, so you need to take a pro-active role to be ready.
As of 1 January 2019, ECHA will start checking the compliance of all relevant dossiers for a given substance and will address its decisions to all registrants with non-compliant dossiers. This is a change from the current practice of addressing mainly the lead registrants. Similarly, the Agency will address its decisions on testing proposals to all those registrants intending to rely on the proposed tests to fulfil their information requirement.
At the same time, the content of ECHA’s decisions will be streamlined to provide more focused justifications for the information requested and clear information to registrants about their legal obligations.
The change aims to support the collaboration and communication between registrants regarding their joint submissions after the substance information exchange forums (SIEFs) ceased to exist as of 1 June 2018. After that date, the registrants of the same substance are nonetheless still bound by the obligation to submit the information on their substance jointly.
In addition, in line with the expectation that registrants are keeping their dossiers up to date, as required by the REACH Regulation, the Agency will no longer consider changes related to the tonnage band, uses or the intermediate status of a registration after a draft decision is notified to the concerned registrants.
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