Second REACH Review Action N° 1: Encourage updating of registration dossiers

The EEB welcomes the measures proposed by the Commission and by ECHA in this document to improve the quality of registration dossiers, however we believe they lack of ambition and that further stronger measures are needed to solve the problem of non compliance.

Poor quality and non compliance of dossiers is a very serious matter. According to the ombudsman the main problem is the systemic shortcoming in terms of a lack of incentives for registrants to update their files, despite an obligation to do so. In fact, there are too many incentives for non compliance, such as the lack of regulatory action, the low chance that a dossier will be evaluated, the lengthy of the process and the softness of enforcement. From a company’s perspective, it is “worth” not to comply and “wait and see”.

Enforcement, transparency and market access are the best incentives for compliance…