The REACH Chromium Metal Consortium has taken over management of the FeCr/ FeSiCr CSR.
*** 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 MetalWith 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. For further information about these Consortia and their activities, please access the web pages of interest via the links above.
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