Data Sharing / LoA

Letter of Access for Data Sharing under REACH

Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) is a regulation of the European Union addressing the production and use of chemical substances, and their potential impacts on human health and the environment. 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 to determine how these can be used safely.

Who should register with ECHA?

 You should register with European Chemical Agency (ECHA) 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.

Every manufacturer and importer should be part of a joint Registration dossier to ECHA documenting the hazard and risk assessments of the chemical substances they supply or use.

Registration is based on the “one substance, one registration” principle. This means that all manufacturers and importers of the same substance have to be part of the same Joint Submission. The Lead Registrant submits 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.

When do you need to register?

As soon as you need to enter the EU market and after submitting an enquiry to ECHA.
For more information, go to the ECHA website.

How to register your substance?

There are two ways:

Become a member of the European Precious Metals Federation (EPMF)

If you wish to register a substance that is already covered by a Joint Submission prepared by the European Precious Metals Federation, is to become a member of the EPMF. Members have the right to participate in the activities of the EPMF, including the General Assembly which is in charge of the workplan (timing and resources).

Copies of the Articles of Association and Internal Rules are available here:

Contact the EPMF Secretariat for Assistance

If you are considering Membership in the EPMF, please contact us directly.

Purchase a Letter of Access

The second option for companies wishing to register their substances, is to buy a Letter of Access. This process allows all companies to share the costs of the registration dossiers and related processes (compliance check, substance evaluation, etc.). The Letter of Access is a short document that grants recipients the 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 chemical safety report (CSR), as well as specific sections of the IUCLID file (REACH database) and some guidance documents.

More information on Letter of Access (LoA) including the 2019 fee schedule is available here:

Contact the EPMF Secretariat for Assistance

If you are considering a Letter of Access, please contact us and provide the following information: