Letter of Access

iFor companies not willing to become a member of i2a, there is a possibility to obtain a right to refer to the REACH Dossiers submitted by i2a Members, and join that existing submission, by purchasing a Letter of Access for a specific antimony substance and REACH tonnage band. 

The LoA option does not involve ownership of any data or studies produced or obtained by i2a, and it does not allow the company to view or to use these data/studies.  The Letter of Access is nominal and both substance and tonnage band-specific. In contrast to full i2a membership, the LoA option also means that no additional help can be expected from the i2a secretariat (for example during registration preparation and submission).

What is included in the Letter of Access? 

  • Signed Letter of Access, which demonstrates that the company has a legitimate right to refer to the joint Dossier prepared by i2a for the Substance and the specified tonnage band;
  • Access to a valid security token number which enables the company to join the relevant joint submission object in the European Chemicals Agency (ECHA) REACH-IT platform; 
  • Access to a pre-completed company individual IUCLID file, to be completed and submitted by the company, in order to become a co-registrant for the Substance and comply with the EU-REACH Regulation; 
  • Access to the non-confidential parts of the Chemical Safety Report (CSR) submitted by the Lead Registrant for the specific Substance, when registered at or above 10 tons/y.
In addition to the above, i2a full members also benefit from additional services (cf. advantages of i2a membership).

What shall the company buying a Letter of Access provide to i2a?
  • The names of all Affiliates to which the rights conferred by the LoA shall exclusively apply; 
  • In case of an Only Representative (OR): the full name of the non-European company and its Affiliates for which this LoA will be used;
  • The highest tonnage band for the Substance, to be registered under EU-REACH by any of the Affiliates reported above;
  • The duly signed Letter of Access Agreement;
  • The amount corresponding to the LoA fee for the given substance and tonnage band.
If a Company requests a LoA close to the registration deadline, the obligations of i2a shall only be obligations of best effort (and not an obligation of result). Neither i2a nor the Lead Registrant can be held liable for the Company failing to meet its registration deadline in this case. I2a recommends that any company wishing to register under EU-REACH, launches the membership or LoA purchase discussions at the latest three months before the applicable registration deadline. 

What is the cost of a Letter of Acces (LoA) 

The price of a LoA is calculated on the basis of a thorough itemization exercise, and on the family (grouping and read-across to minimize the need for animal testing) approach followed by i2a to produce the Registration Dossiers.  Please contact i2a for the latest membership fee and LoA cost. We encourage companies having more than one antimony substance to consider full i2a membership. More information on data-sharing under REACH can be found on ECHA’s website.

It is important to note that according to Article 22 of the REACH Regulation, it is mandatory to keep Registration dossiers up to date without undue delay with relevant new information.  The price of a LoA charged initially by i2a may thereby not cover the total cost of producing and maintaining a dossier up to date. With several antimony substances undergoing Substance Evaluation under REACH, and the grouping and read-across approach embedded in the assessment of all antimony substances, LoA purchasers (as well as i2a full members) should prepare for new information to be required and associated costs invoiced across all relevant registrants. 
International Antimony Association VZW
Avenue de Broqueville 12
BE-1150 Brussels
T : +32 2 762 30 93
F : +32 2 762 82 29
VAT : BE 0894.536.176
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Création site internet | IDcreation 2012 | Last updated: 24/06/2019
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