ECHA to Update EC Number/List Number Format in REACH-IT System

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."

CIRS Insights

The format update is scheduled for implementation in early summer 2025. 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.

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 ton 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.

About CIRS

CIRS Group is a leading provider of comprehensive regulatory compliance services and solutions for chemicals, cosmetics, food and food-related products, agrochemicals, and medical devices. Our chemical team consists of experts with extensive knowledge in chemistry, toxicology, environmental science, and related fields. They are well-versed in various international regulations, including but not limited to EU REACH, CLP, GHS, TSCA, and K-REACH. 

Our chemical compliance services in the EU cover:

• EU REACH Registration (including OR services);
• EU REACH Evaluation Compliance Services;
• SVHC Testing;
• EU CLP Compliance;
• EU Poison Center Notification; and 
• EU BPR Compliance.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further Information

ECHA