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Purchasing a Letter of Access to the Chromium Joint Data Dossier
The price for a Letter of Access (LOA) to the Chromium dossier for a 2010 registration will be 14.000 plus applicable VAT and bank transfer charges. This price is per legal entity that will register in 2010. This price is slightly higher than than the 12.000 tentatively announced on the Consortium website, but there have been some 17.000 of last minute and unanticipated data costs. The possibility of a modest price increase to reflect last minute data costs was discussed in the Cr Metal SIEF Communication document sent to the Chromium SIEF members on 17 June 2010. This price includes a copy of the CSR which you can use to file with your individual registration, but only if your Chromium is of sufficient purity that it is not classified. See Sameness discussion below. There will be a joint submission of the Classification and Labelling as "not classified." Each registrant will need to submit their own "guidance on safe use," however a model Safety Data Sheet will be made available to provide some guidance.
Below is the Process for Purchasing a Letter of Access (LOA) to the Chromium Metal Dossier for the 2010 Registration Deadline. This Information applies to Chromium SIEF members that will register in 2010. No price has yet been set for the 2013/2018 Registration dates.
Members of the Chromium Alloys Consortium and the Chromium Metals Consortium will follow a different procedure.
If your registration deadline for Chromium is NOT 2010, there is no need to do anything now.
Steps to Take to Purchase a Letter of Access to the Chromium Joint Data Dossier 1. Review the Sameness Discussion in the document found at to ensure the composition of your Chrome metal falls within the sameness criteria. Contact estreicher@khlaw.com if this is an issue for your company.
2. Review the Chrome Metal Use Codes at to ensure your uses are covered in the Chromium Metal CSR. You can add additional uses to the CSR that you will submit with your individual registration dossier.
3. Review and Sign the Chromium SIEF Agreement. Each Legal Entity that will Register in 2010 will need to sign a separate agreement. The Chromium SIEF Agreement is found at: http://www.reach-chrome.com/web/chromium%20metal%20consortium%20sief%20interactions/1011306087/list1186151324/f1.html
4. Pdf the Signature Page to estreicher@khlaw.com. The Signature Page is found at
5. Indicate in your e-mail to -- The name(s) of the legal entit(ies) that will register Chromium in 2010 and the UUID number for each legal entity. -- Whether you need access to the Chromium Metal CSR. -- Confirm that the composition of your Chromium falls within the sameness criteria. -- Confirm that your substance is not classified under the Dangerous Substances Directive (DSD) or the Classification, Labelling, and Packaging (CLP) Regulation.
You will need to submit the Cr CSR and Guidance on safe use separately as part of your individual Cr registration. See the following Schedule for Companies that are Not members of the Chromium Metals Consortium, the Chromium Alloys Consortium, or listed in Appendix 3 of the Eurofer Stainless/ISSF Data Referral Right Agreement.
Timing/ Next steps Steps and timing for Companies joining in the 2010 joint dossier:
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