The pre-SIEFs have been set up to establish substance sameness and to reach agreement on classification and labelling. The Chromium Metal Consortium is already engaged in establishing the sameness of the substances that have been pre-registered by its members and is also compiling the relevant compositional, physical, chemical and toxicity data.

If you are within any of the pre-SIEFs for the substances represented by the Chromium Metal Consortium, we would invite you to complete our surveys questionnaires accessed with your login and password (link to the SIEF Communication Tool, see the dedicated section in the following pages).

The Chromium Metal Consortium will analyse the results of these surveys and will contact you to discuss further your registration needs and obligations.

If you have completed surveys and have any questions at this time, please contact us at . You may also contact us if you want to access, update or delete the information provided in surveys.

If you have an interest in joining the Chromium Metal Consortium, the legal documents and joining instructions can be accessed here.

The price for a Letter of Access (LOA) to the Chromium dossier for a 2010 registration at 1000+ tonnes per year, for companies that are neither members of the Chromium Metal Consortium nor Chromium Alloys Consortium, 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.  A SIEF agreement is attached.  We require that you sign the SIEF agreement by 10 August 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.