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 (>1tonne/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 data and assessments.

Registration is based on the "one substance, one registration" principle. This means that manufacturers and importers of the same substance have to submit their registration jointly. The analytical and spectral information provided should be consistent and sufficient to confirm the substance identity. 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 website.


How to get rights to refer to the registration dossier?

1. Become a regular member of the Nickel REACH Consortia

Members of the Nickel REACH Consortia have the right to refer to the joint registration dossier and to participate in the activities of the Consortia, including the General Assembly who takes the decisions related to the approval of the dossier updates and Consortia workplan.

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 joint 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 (only for tonnage band >10t/y), as well as specific sections of the IUCLID file and some guidance documents.

    The Letter of Access fee is composed of 4 elements:

    1. A fee for studies conducted for the EU Nickel Risk Assessment
    2. A fee for the 2007-2010 workplan
    3. A fee for the 2011-2022 workplan (updates of the Dossiers)
    4. A fee for the 2023 workplan (updates of the Dossiers)


    If you consider one of these options please contact us and inform us of:

    • Your status in REACH (Importer/Manufacturer/Only Representative)
    • The substance(s) of interest
    • The tonnage band for which you intend to submit a registration dossier (based on the annual volume of the manufactured/imported substance) and the nickel content in the substance


    When do you need to register?

    Substances need to be registered before being manufactured or imported into the EU in quantities above 1 tonne per year.