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New EU REACH Registration technical completeness checks

ECHA carries out a technical completeness check on each incoming REACH registration and PPORD notification as set out in Article 20(2) of the REACH Regulation. This is done to ensure that the dossiers include all the information that is required. It applies to all registration dossiers submitted to ECHA (both initial submissions and updates).


REACH registration process

SOURCE: ECHA


As of the 1st of June 2023, ECHA introduced new EU REACH registration Technical Completeness Checks (TCCs) for dossiers being submitted via REACH-IT.


List of new and amended REACH registration completeness check rules:


The new TCCs requires:

  1. Product Category (PC) to be associated with each use in Sections 3.5.3 (Uses at industrial sites) and 3.5.4 (Widespread uses by professional workers)

Product category describes type of chemical products in which the substance is finally

contained.


→ Examples: paints, fuels, laboratory chemicals etc.

  • No PC will be required for Intermediate use in Section 3.5.3, as long as the intermediate status is indicated in 'registration / notification status for the use' field of IUCLID.


2. Service life record to be created in IUCLID Section 3.5.6 for any use with the following Environmental Release Categories (ERCs):

  • ERC 8c: Widespread use leading to inclusion into/onto an article (indoor),

  • ERC 8f: Widespread use leading to inclusion into/onto an article (outdoor),

  • ERC 5: Use at industrial site leading to inclusion into/onto an article.

Service life describes use of the substance in an article:

→ Examples: • Dyes in textile articles,

• Plasticiser in articles made from soft-plastic material,

• Flame-retardants in plastic articles,

• Pigment in dried coating after application in/on article.


→ Further information: Q&A 1669, Q&A 1860


If you want to carry out REACH registration, you can read more about the process itself in our blog post entitled REACH registration process.



If you want to obtain REACH registration as soon as possible and affordably, we are the right address for you. We already have many successfully implemented processes and many satisfied customers behind us.


If you need any additional information or explanation please don't hesitate to contact us at info@chem-consulting.si. We are here for you!


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