*** C&L Notification ***

If you are planning to notify for the C&L inventory for chromium because you did not register in 2010, please be advised that the lead registrant for chromium indicated no classification in the joint registration dossier. Therefore, when notifying, you should tick the option of substance not classified. If for some reason you feel that your chromium is classified please contact estreicher@khlaw.com immediately.

Information on SIEF Agreement and Letter of Access for Chrome Metal

With respect to the registration of Chromium metal, the price for a Letter of Access (LOA) to the Chromium dossier for a 2010 registration will be Euro 14.000 plus applicable VAT and bank transfer charges. This includes access to the CSR for Chrome metal but not for Ferrochrome alloys or other Chrome alloys. See:

http://www.reach-chrome.com/web/chrome%20consortia/1011306087/list1186151361/f1.html

We require that you sign the SIEF agreement by 15 October 2010 if you have an intention to register in 2010. We are focusing now on the 2010 registrants. We will not set the price for the 2013/2018 dossiers until closer to the registration date for those tonnages. If your Company has a registration deadline of 2013/2018, but plans to register this year, please contact estreicher@khlaw.com immediately to discuss arrangements.

One point of clarification with respect to the CSR. We are working under the assumption at this time that Cr metal will not be classified. As such, the concept of covering intended uses is not relevant as there will be no exposure scenarios. If it turns out that Cr metal is classified, then the exposure scenarios will need to be developed and the cost of that will be in addition to that quoted. The sameness is 96% purity for Cr metal assuming no impurity causes the Cr metal to be classified as Dangerous/ hazardous under the Dangerous Substances Directive/ CLP. This applies to Cr metal as such. Sameness for Cr as a component of alloys is handled differently. If you produce/ import FeCr/FeSiCr, you will need access to the Ferrochrome alloys CSR separately. Contact estreicher@khlaw.com if that is your situation.

This Consortium was set up by lead companies to represent the interest of EU manufacturers and importers of Chromium Alloys with regard to their obligations under the REACH Regulation. The substances covered by the Chromium Alloys Consortium are Ferrochrome and Ferrosilicochrome.

In drafting the Consortium Alloys Consortium, the lead companies took into consideration, in so far as possible, the comments received by other actors in this industry based on the draft circulated in May 2008.

The firm of Lawyer Keller & Heckman LLP is acting as the depositary of the agreement. For more information on the consortium or admission, please contact Herb Estreicher: estreicher@khlaw.com

This Consortium was set up in April 2009 to represent the interest of EU manufacturers and importers of Chromium metal, with regard to their obligations under the REACH Regulation. It incorporates both Chromium Metal and Chromium by-products such as Carbide, Nitride and Boride.

Although preliminary meetings took place with major stakeholders (LSM & Delachaux) from October 2008, the Chromium Metal consortium is officially effective from 1st May 2009.

Keller & Heckman LLP is acting as the depositary of the agreement. For more information on the consortium or admission, please contact Herb Estreicher or Jean-François Chamaly, the consortium Chairman.

For further information about these Consortia and their activities, please access the web pages of interest via the links above.