Examination of testing proposals

Registrants must submit a testing proposal if they intend to perform a new test listed in Annexes IX and X to REACH. ECHA examines (according to Article 40 of REACH) all testing proposals submitted by the registrants and makes sure that every testing proposal addresses the actual information needed and avoids unnecessary testing, particularly when testing involves the use of vertebrate animals.

Inadmissible testing proposals

There are several reasons for closing a testing proposal examination before referral to the Member State competent authorities. These include the cessation of manufacture or import by the registrant, withdrawal of the testing proposals, and inadmissibility.

Inadmissible testing proposals are those where REACH does not foresee a testing proposal examination. These cases are where:

  1. the proposal is addressing Annex VII and VIII endpoints;
  2. testing is already ongoing or completed;
  3. a testing proposal is submitted instead of test results in response to a previous decision of a Member State competent authority according to Article 16(1) or (2) of the directive for classification, packaging and labelling of dangerous substances (see also Article 135 of REACH). 
  4. a testing proposal is included as a result of an ECHA’s decision on compliance check or substance evaluation.

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