Planned Time Limitation of Registrations and New Requirements for Companies.
In April 2025, the European Commission presented an updated timeline for the fundamental reform of the REACH Regulation during the 44th meeting of the CARACAL committee (Competent Authorities for REACH and CLP). This comprehensive revision is part of the Chemicals Strategy for Sustainability and aims to improve the protection of human health and the environment, while promoting the development of safe and sustainable chemicals. A detailed legislative package is expected by the end of 2025, introducing extensive changes across various regulatory areas – directly impacting manufacturers, importers, and downstream users.
Planned Time Limitation of REACH Registrations to Ten Years
One of the key planned changes is the introduction of a time limitation on REACH registrations. Currently, REACH registrations are valid indefinitely. According to the Commission’s proposal, they will in the future be valid for only ten years. After this period, the registration would expire, and companies would be required to carry out a so-called re-registration in order to continue manufacturing or importing the substance. This re-registration is not intended to be a mere formality. Instead, it would involve reviewing and, if necessary, updating the submitted data. New scientific findings, changes in legal requirements, and practical experience would have to be taken into account. In addition, new testing obligations and fees may apply. The overarching goal of this measure is to ensure the long-term quality and relevance of registration dossiers. The planned change will also have direct consequences for downstream users: they must ensure that they only procure and use substances with valid registrations. If a registration expires and is not renewed in time, legal consequences, supply disruptions, and production delays across the supply chain may follow.
Overview of Additional Planned Changes
In addition to the time limitation of registrations, the Commission's reform proposal includes several other major structural and substantive amendments:
- The existing CoRAP mechanism for substance evaluation is to be replaced by a central authority register to enable more uniform and efficient coordination at the EU level.
- The technical Annexes III and VII–X of the REACH Regulation are to be deleted. Instead, registration dossiers would need to be updated immediately, especially when a substance is classified as a Substance of Very High Concern (SVHC).
- A registration obligation for polymers is planned for quantities of one tonne or more per year. Since polymers have so far been largely exempt, this would present an entirely new regulatory requirement for many companies.
- The SVHC list is to serve not only as an information tool but increasingly as a basis for further regulatory measures such as authorisations and restrictions.
- A uniform digital format for safety data sheets (SDS) is under development. The aim is to significantly improve data quality, traceability, and availability along the supply chain.
Early Preparation Is Essential
Although the planned changes are still in the political decision-making process, it is already clear that regulatory requirements under REACH will increase – both in terms of content and administration. Companies are therefore advised to prepare strategically for the coming changes. This includes setting up a structured deadline and obligation monitoring system, analysing the current substance portfolio, proactively planning potential re-registrations, and strengthening internal resources in regulatory affairs. Existing processes and IT systems should also be reviewed for their suitability in meeting future requirements.
Our experts are here to support you with in-depth knowledge and practical experience – from initial impact assessments to the implementation of concrete measures. Feel free to contact us - we will guide you competently through the REACH reform process.