SIEF interactions

SIEF interactions

The pre-SIEFs have been set up to establish substance sameness and to reach agreement on classification and labelling.

If you are within any of the pre-SIEFs for the substance 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.

Information on SIEF Agreement and Letter of Access for Chrome

 

The price for a Letter of Access (LOA) to the Chromium dossier for a registration at 1000+ tonnes per year, for companies that are neither members of the Chromium Metal Consortium nor Chromium Alloys Consortium, is Euro 14.000 plus applicable VAT and bank transfer charges. The price for a registration at 100-1000 tpa is Euro 10.000 plus applicable VAT and bank transfer charges. The price for a registration at 10-100 tpa is Euro 8.500 and the price for registration at 1-10 tpa is Euro 5000. 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 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 be 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.