Data Sharing / LoA

Who should register?

You should register if you are:

  • An EU manufacturer or importer of substances on their own or in a mixture
  • An EU producer or importer of articles meeting the criteria explained in the Guidance on requirements for substances in articles
  • An “Only representative” established in the EU and appointed by a manufacturer, formulator or article producer established outside the EU to fulfil the registration obligations of importers

REACH requires EU manufacturers and importers of chemical substances (>1 tonne/year) to obtain information on physiochemical, health and environmental properties of their substances and use it to determine how these can be used safely. This means that each manufacturer and importer should submit to the European Chemical Agency (ECHA) a Registration dossier documenting the hazard and risk assessments.

Registration is based on the “one substance, one registration” principle. This means that manufacturers and importers of the same substance have to be part of the same Joint Submission. The Lead Registrant submit the joint registration dossier and each co-registrant has the obligation to submit its own information in its individual dossier.

More information on the REACH Registration process is available in the  dedicated section of ECHA.

How to register your substance?

Two options are available for the Registration of the substances covered by the Precious Metals & Rhenium Consortium:

1. Become a regular member of the Precious Metals & Rhenium Consortium (PMC)
Members of the PMC have the right to participate in the activities of the Consortium, including the General Assembly who is in charge of the Consortium workplan (timing and resources).

Consortium Agreement

2. Purchase a Letter of Access
The Letter of Access (LoA) is a short document that essentially grants recipients the limited and narrow right to refer to the registration dossier solely to register a specific substance under REACH. The recipients’ rights to review/inspect the information submitted is limited to what is strictly necessary.

With a Letter of Access:

  • You can refer to the registration dossier for REACH compliance within the EU (token + name of the Joint Submission)
  • You receive a locked pdf copy of the CSR, as well as specific sections of the IUCLID file and some guidance documents.

More information about PMC membership and LoA (including our 2017 LoA costs and timeline) is available here:

2017 LoA timeline (click to enlarge)

If you consider one of these options please  contact us and communicate the following:

  • Your status under REACH (Importer/Manufacturer/Only Representative)
  • The substance(s) of interest
  • The tonnage band of the substance(s)

To facilitate the communication, please download and complete the two below annexes:

When do you need to register?

As a general rule, substances need to be registered before being manufactured or imported into the EU in quantities above 1 tonne per year. A transition regime was set out in the Regulation for substances already present in the EU market before the entry into force of REACH in 2007. The following Registration deadlines apply to these phase-in substances:

30 November 2010 was the deadline for companies to register substances of which they produce or import more than 1,000 tonnes a year or substances classified as CMRs or very toxic to the aquatic environment.

31 May 2013 was the deadline for registration of substances of which companies produce or import more than 100 tonnes a year

31 May 2018 is the deadline for registration of substances of which companies produce or import more than one tonne a year

Is my substance already registered by the Lead Registrant?

Check our registration status and timeline:

Registration status

2017 Timeline (Click to enlarge)