EcoMundo’s experts manage your requests for Letters of Access (LoA) as Lead Registrant or Member of a joint submission. They also ensure the follow-up and updating of your REACH Registration dossiers in the event of a switch to the next tonnage band, addition of a use, or any other change.
When you are Lead Registrant for several substances and a new Member Registrant arrives for one or more of your substances, you must provide the new arrival with the Letter of Access (LoA), and communicate its content, its costs, etc. This implies being able to go back to dossiers submitted perhaps many years earlier.
EcoMundo’s turnkey service, EcoLoA for LR, is there to manage Letter of Access requests with a very precise methodology:
There is no charge for this management service! Once the LoA transaction is completed, EcoMundo is remunerated by a management cost of the LoA paid by the co-registrant. EcoLoA for LR is the simplest, most economical and optimised method for managing your LoA obligations. In compliance with regulation 09/2016, EcoMundo ensures, on behalf of the Lead Registrant, that the necessary information-sharing conditions are correctly in place for all Members. For example, the Lead Registrant must ensure that new Members share only information concerning their tonnage levels. When the SIEF agreement is signed and the LoA paid for, the Lead Registrant distributes the identification numbers to the Members who have requested a joint submission.
If you are co-registrant of a joint submission who has paid the LoA and subsequently new co-registrants pay the LoA, REACH imposes cost sharing in a fair, transparent and non-discriminatory manner. This implies that the Lead Registrant has the obligation to make refunds. Refunds are usually made at an annual frequency for an amount exceeding €1000 and, depending on the conditions stipulated in the signed SIEF agreement, on an annual basis.
EcoMundo offers EcoLoA for Members, a turnkey service to manage your LoA reimbursements paid to the Consortium or the Lead Registrant.
Our service includes:
EcoLoA for Members is the most optimised, sustainable and economical way to recoup your LoA investments. All members of a joint submission for a given substance are brought together, giving more weight to a LoA claim against the LR or Consortium.
When changing the tonnage band for a substance manufactured in, or imported into, a European country, or adding a new use, your Registration dossier must be updated to reflect the change.
The REACH Regulation operates with four tonnage bands:
EcoMundo’s experts continually monitor the tonnage bands for your portfolio of substances and, when necessary, update the Registration dossier affected.
Attention : as your business grows, it is possible that the 1 tonne/year threshold is reached for some of your substances. In such a case, a new REACH Registration is required.
According to ECHA, "after successfully submitting a registration and getting your registration number, you still have work to do."
As a matter of fact, it is recommended to conduct regular updates of your REACH registration dossier in case of changes in the composition, uses or size of your company, for example.
A registration dossier is made to last over time. However, professional contingencies may involve a loss of data and, as a result, more difficult traceability (e.g. a REACH manager leaving the company).
EcoMundo can handle the complete management of your REACH dossiers in order to guarantee your traceability and ensure your long-term compliance: cost invested and paid, dossier archiving, REACH-IT account password, management of ECHA e-mails, etc.