REACH registration costs is based on:
- Data Fees (LoA)
- Consultancy Fees (Dossier)
- ECHA Fees
“Letter of Access” costs
What is a Letter of Access?
A Letter of Access (LoA) is a document that grants you the right to refer to the Lead Registrant’s (LR) registration Dossier.
Article 10(a) of the REACH Regulation includes:“Except in cases covered under Article 25(3), Article 27(6), Article 30(3), the registrant shall be in legitimate possession of or have permission to refer to the full study report summarized under (vi) and (vii) for the purpose of registration”. The LoA may serve this purpose as proof of the right to refer.
- LoA granting permission to use/refer to a single/set of study(ies) by a Data owner
- LoA that allows a SIEF member to refer to the entire Joint Submission for a certain tonnage band.
The LoA will be useful in case of review by the enforcement authorities, where they ask the registrant for evidence on the fulfillment of the conditions from the above-mentioned article 10.
The costs of a Letter of Access
You have to pay the Letter of Access (LoA) to access the information collected by other members. The cost of the Letter of Access can vary greatly and depends on the size of the SIEF, i.e. the number of pre-registrants and registrants as well as the number of necessary studies. It is important to note that you only pay for the data you need and not all the data held by the SIEF.
EcoMundo can help you find the costs of the LoA of the substances you plan to register.
Molybdenum LoA costs:
Carbon Black LoA costs:
Ethanol LoA costs:
What is a SIEF?
SIEF stands for “Substance Information Exchange Forum” and acts to facilitate the sharing of data but also the costs. Joining a SIEF allows to avoid duplication of studies especially animal testing.
The aim of a SIEF “is to facilitate the exchange of information between potential registrants necessary for the registration of the same substance in order to avoid duplication of studies and to agree on the classification and labeling (CLP regulation) of the substance. The SIEF also serves as a platform of data holders to share their substance data/studies. Moreover, when the available information is not sufficient for registration, a SIEF collectively identifies the need for further studies”.
By joining a SIEF you make the REACH registration process easier for yourself.
The Dossier cost varies and depends on the amount of data you have and/or number of substances you plan to register.
The Dossier cost includes:
- Generation of analytical data if they’re not available
- Dossier constitution with/without risk assessment
- Consultancy fees
- Only Representative services
ECHA Fees for REACH registration
Article 74 of EC 1907/2006 regulation defines fees and charges. The registration costs will depend on the tonnage of your substances but also on the size of your company. However, paragraph 2 of that article states: “A fee need not be paid for a registration of a substance in quantity of between 1 and 10 tonnes where the registration dossier contains the full information in Annex VII.”
NB: A registration must be within a joint submission when the same substance is manufactured or placed on the market by more than one company.
|Individual submission||Joint submission|
|Fee for substances in a quantity of between 1 and 10 tonnes||€1,739||€1,304|
|Fee for substances in a quantity of between 10 and 100 tonnes||€4,674||€3,506|
|Fee for substances in a quantity between 100 and 1000 tonnes||€12,501||€9,376|
|Fee for substances in quantities greater than 1 000 tonnes||€33,699||€25,274|
All Fees are in Euros (EUR)
Please note that discounts exist for micro, small and medium enterprises (SMEs). These discount percentages granted by the European Commission according to the size of the structure are as follows:
- 30% for medium-sized companies
- 60% for small businesses
- 90% for micro businesses
A company is an SME if it meets the criteria of the definition developed in the Commission Recommendation on the definition of micro, small and medium enterprises” (Commission Recommendation 2003/361/EC)
Definition of a micro, small or medium enterprise
- Staff headcount & annual turnover and/or balance sheet total (past 2 years)
Article 2 of Annex to the recommendation sets outs the criteria for determining SME status:
- A medium business is one that employs fewer than 250 people and achieves a maximum annual turnover of €50 million or the amount of the annual balance sheet not exceeding €43 million
- A small business is defined as an enterprise which employs fewer than 50 persons and whose turnover or annual balance sheets does not exceed €10 million.
- A micro-business is defined as an enterprise which employs fewer than 10 persons and whose turnover or annual balance sheet total does not exceed €2 million.
NB: Both conditions are required. In determining the status of SMEs, one should use the last two years before the filing of the registration or before the execution of the act subject to a fee.
Not an SME?
‘Your Europe’ website provides information on European funding programs. You’re eligible if you have:
- Businesses or related organization (business associations, business support providers, consultants, etc.) running projects that further the interests of the EU or contribute to the implantation of an EU program or policy.
- Projects that have a transnational character are well thought out and offer added value.
Check our REACH registration services for 2018
- REACH compliance Service
- REACH consulting Service
- REACH for non-EU manufacturer
- REACH Registration
- Only Representative (OR) service
- REACH Late pre-registration and inquiry process
- Representation of your interests within the SIEF and/or consortium.
- Negotiation on your behalf and purchase of the Letter of Access (LoA) from the Lead Registrant
- REACH letter of access
- Data exchange and drafting of your REACH IUCLID dossier.
- Submission of your REACH dossier to ECHA and follow-up until acceptance
- Delivery of your REACH certificate
- Regulatory watch when needed
Do not hesitate to contact our expert Fang Zhou by phone on +33 (0)1 83 64 20 54 for Europe and for North America please dial + 1 (778) 231-1607 or send an email at [email protected].
Any manufacturer or importer of chemical substances, in amounts greater or equal to 1 tonne/year...
Since it came into force in 2007, the REACH regulation aims at managing substances’ chemical risk...