From 2021 to 2023, ECHA conducted two campaigns on the update obligation of REACH registration dossiers under Article 22, REACH, as part of the REACH-En-Force projects. The first campaign examined 148 registrations of substances listed on Annex XIV, REACH. Only if the use of the downstream users is indicated in the registration dossier, they are allowed to use the substance.

The second campaign evaluated the correct indication of the harmonised classification according to the CLP Regulation in 541 registration dossiers.

A total of 57 registration dossiers were found to be deficient and even after requests from the auditors these deficiencies were not corrected in a timely manner. The companies concerned are reminded by the national authorities of the member states. If necessary, the registrants’ registration will be withdrawn and they will be ordered to pay an administrative fee.

The (planned) REACH En-Force projects can be viewed on the ECHA website.

On 25.09.2023 the comment period on the Annex XV Report on the restriction of PFASs in the EU closed. 5600 comments were submitted, the majority of which are against a general restriction of PFASs.

The public comments can be viewed on ECHA’s site.

RAC and SEAC are evaluating the proposed restriction and take the relevant information received during the consultation into account. The Committees prepare their independent scientific opinions, which are expected in 2024 and will be published on the ECHA website.

With the new REACH-Enforce Project No. 13, online trade in particular will be scrutinised more closely. State and federal authorities have reminded online traders of the labelling obligations of their products, and only in extreme cases have penalties been issued for non-compliance with Regulation (EC) No 1907/2006 (REACH) and Regulation (EC) No 1272/2008 (CLP).

In 2025, inspectors will check online articles and mixtures for compliance with the REACH and CLP Regulations, as well as for compliance with RoHS II and POPs Guideline. The evaluation and a comprehensive report are expected in 2026.

For more information on the REACH-Enforce projects, please visit ECHA’s website.

A pilot enforcement project in 15 participating countries has found that 12 % of inspected products contain substances of very high concern (SVHCs). ECHA informs, that the majority (88 %) of suppliers of these products are failing to communicate sufficient information to their customers about SVHCs in products they supply.

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