REACH dossier updates
Find out which of your REACH registrations need an update, what triggers each and when it’s due.
ProjectsREACH dossier updates
- Imogen Carrow
- Arjun Mehta
- Saoirse Kelly
| Registration | Trigger | Deadline | Status |
|---|---|---|---|
| Pigment Red 53:1 | Carc. 2, harmonised | 1 February 2027 | Expert review |
| 2-Naphthol | Composition | 11 April 2027 | Not started |
| Cyclohexanone | Tonnage band | None set | Drafting |
| DEHT | New identified use | 2 September 2026 | Up to date |
| Ethyl acetate | None found | None due | Up to date |
Pigment Red 53:1 Lead
Status: Expert reviewUpdate due by 1 February 2027
- Change
- Carc. 2 (H351), harmonised
- Rule
- Due the day the classification applies
Your expert signs off each trigger
You get the update register, each update drafted from your last dossier, and the rule behind every deadline.
Approval
Illustrative projectImogen Carrow
Status: ApprovedHead of Product Stewardship, after checking the deadlines for all 4 triggers against their sources
Harmonised classification
Change in composition
Change in tonnage band
New identified use
Foresight does the research
Your team brings what only it knows, and your expert makes the call at each checkpoint.
Tasks
Status: In progressIllustrative project3 of 5 tasks done.
Share your registrations
Your team
Status: DoneFind the triggers
Foresight
Status: DoneAgree the triggers
CheckpointStatus: ApprovedImogen Carrow
Check and draft
Foresight
Status: In progressApprove each update
CheckpointStatus: Not startedImogen Carrow
Kept current once it’s approved
Monitoring watches the measures behind your deadlines. When one moves, Foresight rechecks the registrations it affects, and your expert reviews the change.
Monitoring
Illustrative projectWatching 3 measures behind the deadlines
- Status: To review
CLP Annex VI, harmonised classifications
The 22nd ATP’s classifications applied on 1 May 2026, including STOT RE 1 for n‑hexane. Rechecked, none of the 5 substances is listed.
CLP hazard classes for ED, PBT and PMT
REACH Article 41, compliance checks
What we need from you
Four things, shared at setup before the project starts.
Your registrations
Your REACH registration numbers, with your role in each joint submission.
Your changes
Tonnages, uses, suppliers and processes, with any changes you have planned.
Your dossiers
Your latest IUCLID dossiers, so each update starts from what ECHA holds.
Your approver
The person who agrees the triggers and approves each update.
What teams ask about this project
How do you work out each deadline?
From Implementing Regulation (EU) 2020/1435, which sets one for each Article 22 trigger: 3 months for most changes in your business, 6 months for new hazard knowledge or your own change of classification, 12 months for the chemical safety report, and the day it applies for a harmonised classification. Where one event triggers several updates, they go in one submission by the longest deadline. Where your update depends on your lead registrant’s, the clock starts when ECHA confirms the lead’s update is complete.
Where does the evidence come from?
From the law and the regulator: REACH, Implementing Regulation (EU) 2020/1435, the CLP Regulation and its amendments, and ECHA’s publications. For a change inside your business, such as a new supplier or a new use, it’s your own record of the change. Every deadline links to its source, so your team can check the wording directly.
Does ECHA check whether dossiers are kept up to date?
It does. ECHA ran 214 compliance checks in 2025, covering almost 1,200 registrations. From 2021 to 2023 it screened 689 registrations for outdated uses or a missed harmonised classification, and sent 57 to national enforcement authorities.
Who checks the updates before we submit them?
The person you name. They agree the triggers before any checking starts, and check each drafted update against its sources before you submit it. Nothing is final until they approve it. These checks reduce the risk of error without removing it.
What happens when a rule changes?
Foresight rechecks the registrations it affects, such as when a new harmonised classification is adopted. The register your expert approved stays as it is until they accept the change.
What does it cost?
The price follows the register’s size: how many registrations it covers and how many need an update. You see it with the scope, before any checking starts.
More ways to keep documents current
Each runs the same way, with your expert approving the result.
Bring your IUCLID dossiers to a demo
Tell us your registrations and your role in each. You’ll see the scope and the price before any checking starts.
