On February 18, 2025, the European Chemicals Agency (ECHA) announced via the REACH-IT system that it will adjust the format of the primary substance identifier—the EC Number/List Number. Currently, the format is "xxx-xxx-x" (e.g., "242-xxx-x" or "212-xxx-x"). However, due to the imminent exhaustion of the existing 7-digit numerical format, ECHA will transition to an alphanumeric format while retaining the original length. The new format will follow a structure such as "A00-000-0."
Preparing for EU REACH Registration
Under the EU REACH Regulation, companies manufacturing or importing chemical substances (substances on their own, in mixtures, or intentionally released from articles) in the EU exceeding 1 tonne per year must submit a registration dossier to ECHA. Failure to comply will result in the prohibition of manufacturing, importing, or selling the substance within the EU.
Key Steps for Compliance
1. Pre-registration Inquiry
Before formal registration, all companies (whether pre-registered or not) must submit an Inquiry to ECHA via the REACH-IT system. This step is critical to access existing registration data and determine the need for joint submission. The inquiry dossier must be prepared using the IUCLID software.
2. Joint Submission vs. Individual Submission
Joint Submission Requirement: Multiple companies producing or marketing the same substance must submit jointly. A Substance Information Exchange Forum (SIEF) must be established to share data, allocate costs, and align on classification and labeling.
Lead Registrant (LR) Process:
- The LR submits the registration dossier before the deadline.
- Other registrants submit their dossiers after the LR’s dossier passes ECHA’s business rule validation.
- Registration numbers are issued to the LR once ECHA confirms fee payment. Other registrants receive numbers after their dossiers are deemed complete.
ChemRadar Insights
The format update is scheduled for implementation in early summer 2024. CIRS Group reminds enterprises that this change may impact internal record-keeping systems. Proactive preparation is advised to ensure a smooth transition and data accuracy.
