REACH dossier hidden risks: compliance implications and how to solve them
The Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) is one of the EU’s most demanding and far-reaching chemical regulations, designed to ensure the safe manufacture, import, and use of chemical substances across Europe.
Under REACH, any company that manufactures or imports one tonne or more of a substance per year is legally required to register it with the European Chemicals Agency (ECHA). This registration involves submitting a technical dossier containing critical data on the substance’s composition, uses, hazard profile, and safety measures.
REACH dossiers are not "submit and forget"
A common misconception is that once a dossier is submitted, the compliance process is complete. In reality, REACH mandates ongoing maintenance of dossiers. Companies must keep them up to date to reflect the latest scientific knowledge, exposure data, hazard classifications and regulatory developments.
Yet, despite these legal obligations, many companies have not updated their dossiers since the original 2010 deadline. This widespread oversight is now a serious compliance risk, as ECHA intensifies scrutiny and enforces stricter standards.
Cefic’s 2025 Report: The Wake-Up Call
The latest Cefic REACH Dossier Progress Report (2025) leaves no room for doubt: outdated dossiers are a major regulatory concern. According to the report:
- 73% of lead registrant dossiers re-evaluated in 2024 required substantial updates
- Over 2,500 dossiers were reviewed under Cefic’s action plan last year alone
- Key issues included missing data, outdated hazard assessments, weak exposure information, and non-compliance with updated REACH annexes
- More than 5,000 substances still require updates by 2026
If your company hasn’t reviewed its REACH dossiers since the 2022 annex updates, chances are you’re already non-compliant – and falling behind your industry peers.
What’s at stake: the cost of inaction
Failing to maintain and improve your REACH dossier can lead to severe consequences, including:
- Legal Non-Compliance
- Under Article 22 of REACH, registrants must update their dossiers “without delay” when new information becomes available.
- Failure to do so may trigger enforcement actions by national authorities or ECHA.
- Fines and Financial Penalties
- Non-compliance can lead to substantial fines, which vary by country.
- In some jurisdictions, repeated or serious violations may even result in criminal liability.
- Safety and Liability Risks
- If new hazard or exposure data isn’t reported, companies may be held legally liable for any health, environmental, or workplace incidents.
- This can also result in reputational damage and loss of customer trust.
- ECHA Compliance Checks
- ECHA continues to systematically evaluate dossiers for completeness and accuracy.
- Outdated dossiers may be flagged, delaying business operations or triggering additional information requests.
- Learn more >
- Business and Supply Chain Disruption
- Customers and partners rely on up-to-date safety data.
- A non-compliant dossier may result in the suspension of your REACH registration, loss of EU market access, and supply chain interruptions.
How we can help: REACH Dossier improvement made simple
At Ricardo, we specialise in REACH Dossier Improvement Services that take the burden off your shoulders, so you can focus on running your business while we ensure your compliance.
Our approach includes:
- A comprehensive dossier health check to assess current status and identify critical gaps
- Clear recommendations on what needs immediate attention vs. what can be planned for later
- End-to-end project management with minimal input required from your team
- Confidence that your dossier aligns with current regulatory expectations and scientific standards
Whether you're dealing with a single substance or a complex portfolio, we manage the process seamlessly, efficiently, and fully in line with ECHA requirements.
Don’t wait for enforcement to catch up – get ahead now
REACH compliance isn’t static, it’s a living obligation. With regulatory pressure mounting and over 5,000 substances still flagged for updates, now is the time to act.
Let us help you protect your business, avoid penalties, and maintain access to the EU market with a REACH Dossier Improvement strategy tailored to your needs.
Contact our chemical regulatory and compliance experts today >
