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REACH Focus in 2020

With a Brexit deal all but confirmed, and the negotiations on the future UK/EU trading relationship expected to last until the December 2020 deadline, attention is now turned towards ECHA’s plans to focus on REACH compliance checks during 2020. This means companies need to make sure they are fulfilling their REACH responsibilities and are prepared for possible audits.
The UK looks set to leave the EU on January 31st, initiating a transition period. This transition period is the time for negotiation of the UK’s future trading relationship with the EU and will steer the UK’s future participation in REACH. The transition period has a deadline of December 31st 2020, meaning the REACH focus for 2020 can be shifted for now, and falls mostly on ECHA’s continued scrutiny of REACH registration dossiers.
In the second REACH review (2018), it was found that 1/3 of REACH registration dossiers do not fully comply with EU standard information requirements. To address this shortfall, the European Commission requested ECHA to identify the main reasons of non-compliance and develop a strategy for substance evaluation which encourages industry to improve their safety data on chemicals.{1}

REACH Evaluation Joint Action Plan

Following the request, in 2019, the European Commission and ECHA released the ‘REACH Evaluation Joint Action Plan’ to address the gap in compliant REACH registration dossiers.[2]
Additionally, since 2010, ECHA has gradually moved from compliance checks that were based on random selection of dossiers to an approach where the focus is mainly on those substances that matter the most for human health and the environment. These ‘smart’ compliance checks present an efficient use of resources where targeting can be done with the help of screening tools.[3]
With the most hazardous substances in mind as a priority, the action plan aims to categorise registered substances into one of the following three pools: [4]
  • Of priority for regulatory risk management - substances with an identified concern, with sufficient information to initiate hazard identification, or a restriction or authorisation process. 
  • Currently of low priority for further regulatory action - substances already subject to sufficient regulatory requirements.
  • Of priority for data generation - substances not identified in the 1st or 2nd pool and may still be of concern due to hazardous properties or data gaps preventing a conclusion on risk management action. These substances are prime candidates for compliance checks and substance evaluation.

Compliance Checks

The action plan is already being implemented with ‘Action 1’ where by for 2019, the Commission will propose an amendment of the REACH Regulation to raise the 5% minimum target of dossiers in each tonnage band selected for compliance checking to 20%. This means checks for about 30% of all registered substances. These increased compliance checks have already begun, with 2019 seeing a 50% rise in compliance checks, with the number of substances scrutinised at over 300, and this looks set to intensify in 2020.[5]
‘Action 2’ in the plan states ‘By end of 2020, ECHA will have concluded for all substances registered above 100 tonnes/year if they are i) of priority for regulatory risk management, ii) currently of low priority for further regulatory action, or iii) need more data for a judgement to be made. Substances under iii) are candidates for further compliance check and/or substance evaluation. These conclusions will be made publicly available and will be accompanied by clear communication to all stakeholders involved.’ These points refer to the category pools, where ‘need more data for a judgement to be made’ substances are seen as prime candidates for compliance checks and substance evaluation.
With ECHA now looking to increase the number of compliant registrations through increased scrutiny, audits and enforcement, companies must ensure having up-to-date REACH-compliant registrations to avoid set-backs in their business operations.


How we can help?

Enviresearch has experience in the submission and maintenance of REACH compliant registration dossiers, and is here to assist with a comprehensive range of duties which fall under the REACH regulatory system. Our services include; the preparation of technical dossiers, environmental exposure assessments, ecotoxicology and human health assessments, representation in SIEFs/consortia and acting as an Only Representative for non-EU manufacturers and formulators. For a full list of our services, please see our website, or contact our expert consultants at This email address is being protected from spambots. You need JavaScript enabled to view it..




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