*** C&L Notification ***

If you notified 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 have ticked the option of substance not classified. If you did not do so, we urge you to update your notification. 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 >1000 tpa is Euro 14.000; Euro 10.000 for 100-1000 tpa; Euro 8500 for 10-100 tpa; and Euro 5000 for 1-10 tpa, 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 1 February 2018 if you have an intention to register in 2018. If your Company has a registration deadline of 2018, but plans to register earlier, please contact estreicher@khlaw.com immediately to discuss arrangements.

One point of clarification with respect to the CSR. Cr metal is not classified. As such, the concept of covering intended uses is not relevant as there will be no exposure scenarios. 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.


 FerroChrome 
 FerroSilicoChrome

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 handles Chromium Metal. The Consortium is now organised as a legal entity (ASBL) in Belgium

The Chromium by-products Carbide and Nitride are handled by the REACH Chromium Composites Consortium ASBL. If you have an interest in these substances, contact . If you are interested in registration of Chrome Boride, contact

Keller & Heckman LLP is acting as the depositary of the Consortium 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.