ECHA REACH and CLP Report 2026: REACH Dossier Update Becomes a Core Compliance Priority

REACH Has Moved from Registration Deadlines to Dossier Maintenance

The REACH Regulation (EC) No 1907/2006 requires companies to register substances manufactured or imported into the EU at one tonne or more per year, unless a specific exemption applies. Non-EU manufacturers may appoint an EU/EEA-based Only Representative (OR) to fulfil relevant registration duties for substances imported into the EU.

ECHA’s latest five-year report confirms that the EU chemicals regulatory system has entered a more mature phase. During 2021–2025, ECHA received 18,911 initial registrations and 45,189 registration dossier updates. This indicates that the regulatory focus has shifted from registration-deadline activity to the maintenance and quality control of existing registration data.

A REACH registration is not a one-time obligation. Registration dossiers must be updated when relevant changes occur, including:

• changes in tonnage band;

• changes in identified uses;

• new information on substance properties, hazards or risks;

• changes to classification and labelling;

• revised information requirements under REACH;

• new regulatory obligations affecting the substance.

ECHA noted that 54% of active registrations had not been updated during 2021–2025, and 16% had not been updated in the last 10 years. For companies relying on older registrations, this may indicate a gap between current regulatory expectations and the information available in the dossier.

REACH Compliance Check: Data Quality Remains a Regulatory Focus

Evaluation remains one of ECHA’s main tools for improving the quality of REACH registration data. During 2021–2025, ECHA concluded 1,528 compliance checks and 161 substance evaluations, covering over 10,000 dossiers and resulting in 6,745 requests for additional information.

More specifically, ECHA issued 1,198 compliance check decisions covering 6,693 requests for additional information. Many of these requests concerned data gaps in endpoints that are critical for hazard and risk assessment, including:

• long-term aquatic toxicity;

• mutagenicity and genotoxicity;

• biodegradation;

• reproductive and developmental toxicity;

• environmental fate and behaviour;

• other human health and environmental endpoints.

ECHA also highlighted that timely and comprehensive dossier updates by industry remain necessary to support effective regulatory measures. Older dossiers may rely on insufficiently justified data waivers, adaptations or read-across arguments that no longer meet the current level of regulatory scrutiny.

For registrants, this means that a technically weak dossier can result in formal information requests, additional testing requirements, revised chemical safety assessments and possible follow-up by national enforcement authorities if required information is not provided within the applicable deadline.

Imported Mixtures Are Under Closer Scrutiny

The report also highlights a practical enforcement issue for companies supplying mixtures to the EU. ECHA noted that enforcement results continue to indicate a significant share of imported substances within mixtures that have not been registered.

In the 2024 enforcement project, non-compliance with the registration obligation was 7% for substances imported on their own, but reached 32% for substances imported in mixtures. This suggests that EU importers and non-EU suppliers may not always have sufficient visibility over the registration status of substances contained in formulated products.

This issue is relevant for sectors such as:

• coatings and paints;

• inks and pigments;

• adhesives and sealants;

• lubricants;

• cleaning products;

• surface treatment products;

• industrial and specialty formulations.

Companies should not assume that a final mixture can be placed on the EU market without checking the REACH status of its individual substances. Where a substance in a mixture is imported into the EU at one tonne or more per year, the registration obligation may apply unless an exemption is available.

For broader EU market access planning, companies may also need to consider related obligations under REACH, CLP, SVHC communication, PCN and other EU chemical compliance frameworks. REACH24H’s One-Stop Compliance Solution for Exporting Chemical Products to the EU is designed to help companies assess these obligations together rather than in isolation.

Impact & Actionable Advice for Multinational Companies

ECHA’s 2026 report shows that REACH compliance is becoming more data-driven and enforcement-oriented. Companies placing substances or mixtures on the EU market should treat dossier management as an ongoing compliance process.

1. Review Existing REACH Registrations

Companies should conduct a structured review of existing registrations to confirm whether the dossier remains aligned with current regulatory and business conditions. The review should cover:

• legal entity and Only Representative arrangements;

• substance identity and sameness;

• tonnage band;

• registered uses;

• exposure scenarios;

• chemical safety report;

• classification and labelling;

• endpoint data completeness;

• waiving and read-across justifications;

• confidentiality claims and public information on ECHA CHEM.

2. Prioritise Dossiers with Higher Evaluation Risk

Higher priority should be given to dossiers involving:

• high tonnage bands;

• hazardous classifications;

• substances with SVHC, restriction or harmonised classification relevance;

• older registrations that have not been updated for several years;

• dossiers relying heavily on adaptations, waiving or read-across;

• complex substances or UVCBs with limited supporting data.

Early technical review can help companies identify whether additional data, stronger scientific justification or updated exposure assessment is needed before ECHA initiates a compliance check.

3. Verify REACH Coverage for Mixtures

Suppliers of mixtures should map the substances contained in products placed on the EU market and confirm whether:

• the relevant substances are registered or exempt;

• the tonnage band covers actual EU import volumes;

• the registered uses cover the intended use in the mixture;

• EU importers and ORs have clearly allocated responsibilities;

• Safety Data Sheets and exposure scenario information are consistent across the supply chain.

Where SDS, labels or hazard communication documents also need to be updated, companies may consider REACH24H’s Global GHS/SDS/MSDS/Label compliance support.

4. Link Dossier Updates with Regulatory Monitoring

REACH registration data increasingly supports wider regulatory actions, including SVHC identification, restrictions, authorisation and harmonised classification under the CLP Regulation. Companies should therefore connect dossier maintenance with substance portfolio monitoring and EU regulatory intelligence.

How REACH24H Can Help

REACH24H supports global companies in managing REACH obligations throughout the full product lifecycle. Our services include:

• EU REACH Registration and Only Representative Services: REACH obligation assessment, OR appointment, dossier preparation, submission and post-registration maintenance;

• One-Stop Compliance Solution for Exporting Chemical Products to the EU: integrated support for REACH, CLP, PCN, SCIP, SVHC and EU market access requirements;

• Global GHS/SDS/MSDS/Label Services: SDS authoring, SDS review, label verification and supply chain hazard communication;

• EU CLP Compliance Support: classification and labelling review where REACH dossier updates interact with CLP obligations.

For companies with existing REACH registrations, REACH24H can help assess whether dossiers remain compliant, identify data gaps and develop a practical update plan before regulatory action creates business disruption.