ORO Position Paper: Must a REACH registration be deactivated if there are no imports?
Auditors recently asked the ORO: Why hasn’t this registration been deactivated if there were no imports for several years?
The short answer: There is no legal requirement to deactivate a registration just because imports have paused. Fluctuations in demand are normal, and deactivating/re-activating dossiers adds administrative burden without improving safety.
The decision to declare “cessation of manufacture/import” rests with the Principal. But when is it actually necessary?
Read our new position paper to understand the legal background (Article 22 & Regulation 2020/1435) and why temporary import pauses do not require immediate action.