Letter of Access

LOA are available for a full dossier and for intermediates.

Read the informatory letter in case you have not received this letter via SIEF-mailing.

Please note that you need to purchase a Letter of access for each affiliate of your company.

If you are an ONLY REPRESENTATIVE you may use the LOA for a full dossier and indicate so on page one. Please note that you will need to purchase a letter of Access for each company that you represent.

If your company purchased an LOA for the REACh registration of substances covered by the SDIOC substance portfolio before June 2015 please note articles 4 and 5 of the agreement.

Quote:

Art 4. If it becomes apparent - irrelevant if before or after the submission of the Joint Registration Dossier - that the actual costs are higher than assumed for the calculation of the payment set out under paragraph 2, SDIOC has the right to adjust the payments by requiring additional fair, transparent and non-discriminatory payment from Company in accordance with the calculation scheme as negotiated.

Art 5. If it turns out that more SDIOC members and/or more Companies acquiring a Letter of Access than assumed under no. 2 of this Agreement take part in the joint submission, a respective refund shall be made to the company thereby taking into account any other supplemental costs which would justify an additional fee according to no. 4. or no. 6 lit. k) of this Agreement. For refunds a threshold of 1.000 € is applicable. If the Company wishes to re-coup costs less than 1000 €, it will bear the administrative and accounting costs of retrieving such refunds.

Unquote

Reimbursement

After the registration deadline (May 2018) SDIOC conducted the first Reimbursement Mechanism Exercise in the second quarter in 2019. With the Reimbursement Mechanism Exercise the cost price of the LOA for each registrant as regards to each substance was assessed. The Reimbursement Mechanism Exercise takes into account the number of registrants for a substance in a particular tonnage band and the initial payment made by each LOA purchaser and SDIOC member respectively. The LOA payment made by each registrant was taken into account and will be offset against the actual cost for the individual registration. Depending on whether the LOA cost price exceeds or comes within the LOA Payment, each SIEF member will receive a credit note or an invoice for additional payment.

Each SIEF member shall continue to benefit from the rights of access to data needed to register the substance/s under REACH as long as relevant invoice(s) are fully paid by relevant deadlines. SDIOConsortium continues to review available data and update the dossiers as required. The Reimbursement Mechanism Exercise will be repeated every two years (2023, 2025, 2027 and so forth).

Data use outside the EU

If you require access to data compiled in our dossiers under the EU Reach regulation, to be used under any Non-EU legislative (e.g., UK Reach, K-Reach, KKDIK, Biocidal products, etc.) please contact us. We have agreements in place to negotiate access to SDIOC owned data for the use outside the EU. Please contact the Sulfur Dioxide Based Chemicals REACH Consortium (SDIOC) for further information via email SIEF@SDIOConsortium.com.

Information

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This web site contains guidance and information explaining the REACH obligations and how to fulfil them. The REACH Regulation is the only authentic legal reference and all users are reminded the information published on this website does not justify any legal advice. SDIOC and the Consortium REACH Manager/secretariat do not accept any liability concerning the content or use of information published on this website. Full disclaimer