Your REACH Only Representative for non-EU substance manufacturers

SIEF and Letter of Access, explained

Most substances imported into the EU are already registered. To register the same substance, you share the existing data instead of repeating tests - usually by buying a Letter of Access.

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Joint submission (Article 11) Data sharing (Implementing Regulation (EU) 2016/9) Fair, transparent, non-discriminatory costs Avoids duplicate animal tests

What a SIEF is

A Substance Information Exchange Forum (SIEF) brings together the companies registering the same substance so they can share data and avoid duplicating studies, in particular tests on vertebrate animals. SIEFs were formed for substances pre-registered before the 2018 registration deadline; for other cases, a potential registrant contacts the existing registrants after an inquiry to ECHA. In practice, the lead registrant or a consortium manages the data and the Letter of Access.

What a Letter of Access gives you

The right to refer to the jointly submitted study data in your own registration
Access to the joint submission in REACH-IT so you can submit as a member registrant
Coverage for a defined tonnage band - a higher band usually costs more

Rules on cost sharing

Implementing Regulation (EU) 2016/9 requires data-sharing costs to be determined in a fair, transparent and non-discriminatory way. A potential registrant can ask for an itemised breakdown of the costs, and costs are shared only for the data the registrant needs for its band. If negotiations fail, ECHA runs a data-sharing dispute procedure.

Before you buy an LoA, check

Substance sameness

Your substance must match the registered substance identity profile.

The right tonnage band

Buy for the band your OR will register, with room for growth.

Uses covered

Check that the chemical safety report covers your customers' uses.

Who holds the LoA

With an OR, the LoA is bought for the OR's registration on your behalf.

Frequently asked questions

Do I always need to buy a Letter of Access?

Usually, when the substance is already registered and you need to refer to the existing data. You can also provide your own data, but you still have to be part of the joint submission.

Can the lead registrant charge any price for an LoA?

No. Implementing Regulation (EU) 2016/9 requires fair, transparent and non-discriminatory cost sharing, and you can ask for an itemised breakdown. Disputes can be brought to ECHA.

Who holds the LoA when I use an Only Representative?

The LoA is obtained for the OR's registration, which the OR holds on behalf of the non-EU manufacturer.

Check whether you need a REACH Only Representative

Tell us your substance, tonnage band and where your company is established. Before you sign a mandate, we tell you what the next step is.

Free eligibility check