Letter of Access

The International Antimony Association (i2a) hereby outlines the option of a Letter of Access (LoA) for intending registrants of the antimony substances covered by the i2a association that prefer NOT to become member of i2a. A LoA will grant you a 'permission to refer' to the technical dossier for the specific purpose of making your REACH registration if you prefer NOT to become member of i2a. The Letter of Access option does not involve ownership of any data or studies produced or obtained by i2a, and it does not allow the company access to view or to use these data/studies. In contrast to full membership, the LoA option also means that no additional help can be expected from the i2a secretariat.

Available to whom?

A LoA will be sold per legal entity and per substance and will in principle be available to ALL companies as of Q3 2010 for antimony metal, diantimony trioxide and sodium hexahydroxoantimonate. Key market players will be encouraged to go for the membership option to ensure all key players take up their responsibility together. i2a and its members take regulatory issues very seriously and continue to invest in scientific research not only for REACH purposes, but to comply with worldwide regulations/legislations.

Advantages of membership

i2a is offering its members help with preparing the company specific IUCLID file (i.e. sections 1, 3 and 11)
i2a is offering its members an on-site visit by a member of the i2a secretariat to help the member with the actual registration/notification.
i2a provides its members a template for the Safety Data Sheet for antimony metal, diantimony trioxide, sodium hexahydroxoantimonate
The membership fee is based on the total tonnage of all substances of all your legal entities.
Members have voting right (influence the REACH dossier and the work done by i2a).
i2a is also a helpdesk for REACH questions.
Members get answers to all their regulatory questions, not just on REACH.
The data can be used worldwide, not just for REACH.
i2a is a nonprofit association. The more members join i2a, the less all members pay.

No further assistance/support on REACH or any other regulatory issue will be provided by the i2a secretariat to the companies buying a LoA.

Data available

The EU Risk Assessment on antimony trioxide was finalized in 2008 after being peer reviewed by all EU Member State and OECD experts. As i2a is preparing the REACH dossiers for 10 antimony substances and not just for antimony trioxide, further data has been developed over the past months. As data gaps remain for the Sb(V) dossier,study proposals have been included in this REACH dossier that will have to be worked out further based on ECHA’s advice.

Cost of membership compared to LoA cost

The following amounts are applicable ONLY to the three substances that will be registered in 2010: Sb metal, antimony trioxide and sodiumhexahydroxoantimonate. The prices below may not include the total cost. In case the REACH Dossier needs to be significantly updated, companies that bought a LoA will have to pay at that moment their fair share of the costs encountered. A significant update can be, among other things, a study proposal included in the Dossier that have to be worked out further based on ECHA’s advice, new exposure scenarios to add or existing ones to adjust if a new application which is not yet covered comes up, extra work for the HH consultant if during the evaluation of the Dossier by the Member State further details are required, etc. The board of i2a will decide whether or not the update will be needed and whether or not the companies that bought the LoA will be charged additionally for it.

Tonnage	Tonnage band	Indicative membership fee (for 13 years of RA and REACH from 2000 to 2012)	LoA cost
< 10T	XXS	23,613 €	16,000 €
10 - 99T	XS	32,226 €	32,000 €
100 - 999T	S	76,677 €	75,000 €
1000 - 1999T	M	111,129 €	Membership fee
2000 - 4999T	L	197,258 €	Membership fee
5000 - 10,000T	XL	369,515 €	Membership fee
> 10,000T	XXL	541,773 €	Membership fee

What is included in the Letter of Access

Access to the Chemical Safety Report (CSR) for the Substance registered at or above 10 tonnes as submitted by the Lead Registrant;
Access to a valid security token granted by ECHA to the Lead Registrant for antimony trioxide which shall enable the company to participate in the joint submission of the Registration Dossier;
The right to participate in the Joint Submission;
The right to refer to the Dossier for the sole purpose of supporting the company’s registration of antimony trioxide in accordance with the REACH Regulation;
Agreed classification and labeling.

What shall the company buying a Letter of Access provide to i2a?

The names of all the Affiliates to which the rights conferred by the Letter of Access shall exclusively apply.
In case of an Only Representative (OR): the full name of the non European producer and its respective Affiliates for which this Letter of Access will be used.
The average annual tonnage per substance produced in or imported into the EU by each Affiliate in the three calendar years prior to the date of signature of the Letter of Access Agreement.

If a Company would request a Letter of Access 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 his registration deadline in this case.

If you are interested in becoming member, please contact us at

If you prefer the option of buying a letter of access please fill in and sign the below Letter of Access Agreement and send it to us by e-mail (reachatantimony.be) AND the original version by post to the following address :

Nathalie Francis
Office Manager

Avenue de Broqueville 12
5th floor
1150 Brussels
Belgium