Registration must be completed before placing a substance on the EU market (manufacture in or import into the EU). There are two routes - consortium membership or Letter of Access. Letter of Access is the simpler route and allows a legal entity to become a member of the joint submission and benefit from access to the information submitted by the Lead Registrant / The Iron Platform on behalf of the consortium members. Consortium membership brings additional benefits. REACH registration is the responsibility of each Legal Entity.
Letters of Access for iron and iron substances are available for purchase by all interested parties by application to Iron Platform Services Limited.
There is a separate Letter of Access for Only Representatives. Letters of Access are available on a per legal entity basis – they can if needed cover more than one substance.
If you wish to purchase a letter of access to the di-iron trioxide, tri-iron tetroxide or iron oxide hydroxide dossiers, please contact the Iron Oxides REACH Consortium (see contact details).
If you are a legal entity undertaking recovery of iron and wish to take advantage of the exemption granted under Article 2.7 [d] of the REACH regulation [Regulation (EC) 1907/2006 please see the guidance below.
Fee structure and tonnage guidance
A review of The Iron Platform Letters of Access for iron and iron substances and associated fee structure was last conducted in 2023.
How to apply for a Letter of Access
If you intend to apply for a Letter of Access please do so in good time – note that the tokens to join the Joint Submissions will not be issued until payment has been received in full. Our goal is to issue tokens within seven working days of receipt of payment.
Purchase of a Letter of Access from The Iron Platform will involve the following steps:
- submission of a completed online Application Form for Letter of Access – Standard or Only Representative (OR)
- submission by email of the completed and signed Letter of Access Agreement (see Agreement for details of deliverables)
- an invoice will be emailed by Iron Platform Services Ltd. [IPSL] in PDF format (our target is to send the invoice within seven working days of receipt of application forms)
- following receipt of payment in full (i.e. free of all bank charges), IPSL will sign and return the Letter of Access document by email, together with the token[s] for the Joint Submission[s] in the ECHA REACH-IT system.
To apply for a Letter of Access you must submit both an online Application Form AND a signed Letter of Access Agreement
Next steps
Once you have received the signed Letter of Access and token[s] for the Joint Submission:
- join the Joint Submission with the token provided. Log into your REACH-IT account, enter the menu and locate the “Joint submission” section, then click on “Join Existing,” enter the joint submission name and token and follow the steps.
- co-registrants should then submit their own registration dossiers to ECHA.
The Iron Platform has prepared guidance documents on iron and iron substances aimed at helping you prepare and submit your registration dossiers.
Recovery of iron – exemption from registration
REACH Article 2.7 [d] (Regulation 1907/2006) provides for the following exemption from the obligation to register:
substances, on their own, in preparations or in articles, which have been registered in accordance with Title II and which are recovered in the Community if:
[i] the substance that results from the recovery process is the same as the substances that has been registered in accordance with Title II; and
[ii] the information required by Articles 31 or 32 relating to the substance that has been registered in accordance with Title II is available to the establishment undertaking the recovery.
The company undertaking recovery can benefit from REACH Article 2.7 [d] exemption provided that the company has available (i) Safety Data Sheets (SDS) or (ii) when SDS is not required, the registration numbers and information on risk management measures. When using SDS or information on risk management measures the company must make sure that they have legitimate access to the information, and that the hazard profile of company’s recovered substance is adequately covered.
The Iron Platform will prepare guidance for safe use / risk management measures for Iron. This information will be made available to companies undertaking recovery of metals for a nominal fee of €650. This fee reflects the Iron Platform’s effort and cost of preparing the information and is lower than the cost of obtaining access to the REACH registration dossier for the lowest tonnage band of iron. It also incorporates an administration fee of €150.
In order to obtain the required information:
- download the Recyclers Information Provision Letter Agreement
- complete and sign the agreement and send it to us by email
- an invoice will be sent to you which must be paid in full (i.e. free of all bank charges)
- you will then receive the required information and a counter-signed copy of the agreement.
The Eurofer position paper entitled Steel Industry Approach on Steel Scrap and REACH is a useful reference in this context.