Ethanol

This section contains information on how to apply for membership or purchase a Letter of Access for the registration of ethanol.

There are two ways of obtaining the information necessary for the registration of ethanol under REACH: (1) membership of EtOH-REACH and (2) the Letter of Access option.

Option 1. EtOH-REACH Membership

Legal entities can register for membership of the EtOH-REACH association by completing the folowing document: membership form

As soon as we have received the registration, we will send the legal entity an invoice. Only upon payment of this membership will the legal entity become an official member of EtOH-REACH.

Membership of EtOH-REACH will give you:

  • The ‘right to refer’ to the Lead Registrant dossier for the sole purpose of making its REACH-registration for that substance. The lead registrant has jointly submitted the IUCLID dossier chapters 2, 4, 5, 6 and 7 plus the guidance on safe use.
  • The ‘token’ that enables the legal entity to ‘join the Joint-Submission’ in ECHA REACH-IT.
  • A Chemical Safety report (CSR) including details of the agreed classification and labeling and all identified uses for the substance according to what is known by the Association.
  • A prepopulated template of the individual parts of the Dossier
  • The option to view recordings of the registration guidance webinars free of charge


Once you have paid your invoice, you can ask the Secretariat for the token and joint submission name. In order to speed up the procedure, it is recommended that you send proof of payment to the Secretariat of the Association.


You can also request a password to enter the Members’ Area of the EtOH-REACH website, where you can download the CSR and pre-populated template. Here you can also view the instructions on how to use these documents and how to complete your individual registration.

Option 2. Letter of Access

The Ethanol REACH Association [EtOH-REACH] has made the Letter of Access available for purchase for non-members of EtOH-REACH who intend to register ethanol.

A. The Letter of Access grants:

The Letter of Access grants your legal entity the right to refer to the technical parts of the Registration of the Lead Registrant as a co-Registrant for the purposes of Joint Submission. The Letter of Access does not involve granting of ownership of any data or studies produced or obtained by the Association, and it does not allow your company access to view or to use these data/studies.

B. If a company purchases a Letter of Access, it receives from EtOH-REACH:

  • A Letter of Access document confirming that the legal entity has the ‘right to refer’ to the Lead Registrant dossier for the sole purpose of making its REACH-registration for that substance. The lead registrant has submitted jointly the IUCLID dossier chapters 2, 4, 5, 6 and 7 plus the guidance on safe use.
  • The ‘token’ that enables the legal entity to ‘join the Joint-Submission’ in ECHA REACH-IT.
  • A Chemical Safety report (CSR) including details of the agreed classification and labeling and all identified uses for the substance according to what is known by the Association.

Your legal entity will remain responsible for completing aspects of your registration not covered by the Letter of Access.

C. When and how to buy a Letter of Access:

EtOH-REACH has created a Letter of Access order form and Letter of Access agreement. Your legal entity can buy a Letter of Access according to the following instructions:

  1. Your legal entity sends a completed and signed Letter of Access agreement  and a completed Letter of Access order form by e-mail and by post.
  2. After a signed copy of the Letter of Access agreement and the completed Letter of Access order form have been received by EtOH-REACH from your legal entity, EtOH-REACH sends you an invoice by E-mail and post.
  3. After your legal entity has made full payment (registered by the bank of EtOH-REACH), EtOH-REACH will send your legal entity the Letter of Access and the Chemical Safety Report by E-mail, and original copies by post. EtOH-REACH will also send you a signed original of the Letter of Access Agreement by post.
  4. EtOH-REACH will provide your legal entity with the ‘token’ to ‘join the oint-submission’ for ethanol in the ECHA REACH-IT system. In the event that the token has expired prior to your legal entity submitting its co-registration, EtOH-REACH will provide a new token.

D. How to use the Letter of Access:

  1. Your legal entity finalises its registration using IUCLID6 by completing sections 1 and 3 and any other relevant sections and attaching the CSR.
  2. Your legal entity then confirms its membership of the joint submission for ethanol in REACH IT using the ‘token’ after which it can submit its registration.

E. Costs of the Letter of Access

EtOH-REACH considers that all the costs incurred to date in preparing these technical elements of the registration for ethanol and a provision for future costs associated with this work by the Association should be considered in calculating the costs of the Letter of Access. This includes all technical costs relating to the data/studies, exposure assessments, and dossier preparation as well as the management costs relating to the preparation of data-sharing agreements and managing communications (e.g. questionnaires to the SIEFs). 

On this basis, it has been decided to set the price for a Letter of Access as the same as membership of EtOH-REACH:

Ethanol   substance tonnage

Letter   of Access (Euros)

<100   tonnes per year

420   euros + 250 euro handling fee *

Between   100 and 1000 tonnes per year

1400  euros + 250 euro handling fee*

>1000   tonnes per year

14000   euros + 250 euro handling fee*

*This price is valid until 1 December 2018. After this date, the price for the Letter of Access will be recalculated.

Important Notes:

  1. Letter of Access will be available and must be purchased on a per legal entity basis.
  2. An Only Representative or a Third Party Representative will need to purchase a Letter of Access for each legal entity it represents that wishes to register for ethanol.


Finally, please note that in addition to EtOH-REACH Membership or the  Letter of Access fee, the registrant will have to pay a registration fee to ECHA. For more information on this fee, please see the ECHA website.

Documents:

 

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