Turkiye-REACH (KKDIK) Letter of Access (LoA)

What is an IMOA Turkiye-REACH Letter of Access (LoA)?

LoA Background and context: IMOA has granted a Licence to Use IMOA-owned data to the Turkiye-REACH Lead Registrant (LR), to use the technical data generated and owned by IMOA, exclusively for the purpose of generating and submitting the LR technical data to the Turkish authorities, for regulatory compliance with Turkiye-REACH by 31 December 2023.

The Letter of Access, for co-registrants, is a document that grants you the right to:

• refer to the Lead Registrant (LR) registration dossier for the sole purpose of making your Turkiye-REACH-registration for a specific substance.
• participate in the Turkiye-REACH Joint-Submission.

General background to Turkiye-REACH

What does an LoA look like?

View sample LoA for an applicant Company
View sample LoA for an applicant Only Representative

What does it cost to buy an LoA?

CMR = Carcinogenic, Mutagenic, Reprotoxic
H400/H410 = Very toxic to aquatic organisms (acute or chronic)

Important Notes:

LoAs are issued on a per substance, per legal entity basis.

If you are an Only Representative or a Third Party Representative, you will need to purchase a Letter of Access for each company and each substance you represent.

For which substances is an IMOA LoA available?

Further substances may become available if Lead Registrants are appointed within the Turkiye-REACH substance pre-registrant groups. Such LR appointments are outside the scope of IMOA, but LRs for other molybdenum substances are welcome to contact IMOA to obtain a data-sharing Licence.

LoA availability for Molybdenum Trioxide: up to and including the 100 – 999 tonnes tonnage band.
LoA availability for Diiron Trimolybdenum Dodecaoxide: – up to and including the 10-99 tonnes tonnage band.

If I buy an LoA, what do I get?

• Letter of Access document signed by the International Molybdenum Association ( as Secretariat to the Molybdenum Consortium) confirming that you have the ‘right to refer’ to the Turkish-REACH Lead Registrant dossier for the sole purpose of making your Turkiye-REACH co-registration for that substance. It will also require you to maintain confidentiality of dossier data.
• After payment for the LoA has been received and the LoA signed by yourselves and IMOA, the Lead Registrant will grant you access to the Turkiye-REACH Joint Submission.
• Access to the Chemical Safety Report in English for that specific Turkiye-REACH substance.
• Classification & Labelling information.
• List of substance Uses.
• Access to Safety Data Sheet, or where appropriate the e-SDS including Exposure Scenarios, in the English language.

How can I buy an LoA?

Please use the online ordering link at the top of this webpage.

The way it works is:

• After receiving your LoA Order Form, IMOA sends you the LoA invoice for payment, and the LoA Agreement for your signature and return to IMOA for counter-signature.
• After full payment (cleared funds in bank) has been received, IMOA will send you the counter-signed LoA by E-mail.
• By email, cc to you, IMOA will confirm to the Lead Registrant that your company has completed the necessary steps to be granted access by the LR to the joint submission.
• IMOA will provide you with the IMOA English language SDS template (or e-SDS where required for the substance).
• The Lead Registrant will provide you with the Chemical Safety Report, that includes the Classification & Labelling information, and the list of substance uses.

And what happens after that?

• You submit the co-registration that you have prepared, to the Turkish authorities.
  See the Turkish language guidance document for more detail.