Dossier Updates - Mn, MnSO4, MnO2

Under REACH Registrants are obliged to update their dossiers and in many cases, without undue delay. In 2020, the Commission clarified the terminology - without undue delay as follows:

"A deadline of three months applies for administrative updates, such as a change in a registrant’s status or identity. Meanwhile, a deadline of six, nine or 12 months applies for more complex updates, for example when the classification and labelling of a substance without a harmonised classification changes, or there are changes in the chemical safety report or guidance on safe use. However, when there are multiple reasons for updating a registration, only one submission is required and the longest deadline applies..."

To this end, the following dossiers were updated for the following reasons:

Mn  (EC Number: 231-105-1) - CSR update triggers Dossier update: Focus: The 2010 life cycle tree and chemical safety report (CSR) did not accurately reflect the current situation. Therefore,interviews and co-registrants questionnaires provided information covering the entire supply chain – mining, smelting and trading. This more uptodate information was used to revise the understanding of the manganese metal processes, uses and exposure patterns. This was used to update the CSR.

MnSO4 (EC Number: 232-089-9) - CSR update triggers dossier update: Focus: on use and exposure. Assessment reveals all uses from the original dossier ( 2010)are still considered as safe but for consumer use of fertiliser products - PC 12: Fertilisers where only 12.5% of the registered substance can be used in fertilisers. Any concentration above this will lead to significant effects hence falling the risk assessment and triggering a use advised against.

MnO2  (EC number: 215-202-6) - LR request to update supply chain changes

Based on the above updates, a new update CSR is available for those co-registrants that are uptodate with the LoA payments. Please request your new CSR from reach@manganese.org. Note that you are encouraged to update your own joint dossier and use the information inherent in the updated CSR's in your SDS's