Why you should join the REACH Chrome Alloys Consortium

REACH places significant burden on individual companies and the obligations under the REACH Regulation will notably lead to a lot of costs for these companies.

In addition, REACH creates obligations on companies to work together for the fulfilment of their individual obligations. First, REACH creates an obligation on potential registrants of the same substance to collaborate within the Substance Information Exchange Forum (SIEF) and eventually share certain data. Moreover, the REACH Regulation imposes an obligation on the registrants of the same dossier to submit jointly the technical part of the technical dossier.

In view of the above described obligation, the advantages of joining the REACH Chrome Alloys Consortium can be summarised as follows:

• Pooling of resources and costs reduction for:
• Existing Study reports/Data
• In-house expertise
• Cost-sharing for chemical safety report and testing
• Budget and plan for compliance in a transparent and managed structure.
• Work with categories of substances as opposed with one substance per SIEF.
• Vertebrate animal studies must be shared in any event and within the Consortium, vertebrate animal studies owner can ensure that the consortium members will reimburse a portion of the testing costs it had to bear.
• Lead Registrant can work to ensure that the best scientific case is developed and that the Classification and Labeling is accurate and uniform
• Consortia members benefit from reduced registration fees
• Individual dossiers will have priority attention for Evaluation
• Coordinated responses to agency, joint appeals of test requirements
• Protection of Confidential information
• Protection against the risks associated with competition law
• Develop a strong, collective approach to regulatory authorities for decisions made jointly.

In addition, in view of the registration strategy of the alloys, joining the Consortium has many additional advantages:

FeCr and FeSiCr have been pre-registered with the European Chemicals Agency as special preparations. This registration strategy implies that each individual metal component of the alloys be registered.

However, note that the impurities (such as Carbon, Nickel and Manganese) need not to be registered under the special preparation registration route; they only need to be taken into consideration in the Chemical Safety Report (CSR) related to the alloys. In the case of FeCr and FeSiCr, the CSR provides all of the data on the alloy as such and sets out the exposure scenarios and conditions for safe use of the alloys. There aspects are not addressed in the CSRs for the individual metal components. Accordingly, in order to register FeCr and FeSiCr one is required to have access to the ferochrome alloys CSR.

In practice, for the registration of alloys, a registrant needs to submit:

• A letter of access to the Iron dossier developed by the Iron Platform. Note that the Chromium Alloys Consortium will be benefiting from a Group Membership to the Iron Platform granting the Members of the Alloys Consortium the letter of access to the Iron registration dossier. Non-Members of the Chrome Alloys Consortium will have to negotiate access to the dossier with the Iron Platform on their own.

• A letter of access to the Chromium Metal dossier. Note that there is a collaboration between the Chromium Metal and the Chromium Alloys Consortium regarding access to the Chromium dossier. Non-Members of the Chromium Alloys Consortium will have to negotiate access to the dossier with the Chromium Metal Consortium on their own.

• The Chemical Safety Report on FeCr and FeSiCr. The Chrome Alloys Consortium will be selling a Letter of Access to the registrants of FeCr and FeSiCr who are not Members of the Consortium.

• And for FeSiCr: the registrants also need to obtain a Letter of Access to the Silicon dossier developed by the Silicon Consortium.

By being part of the Consortium, you will benefit from the work already carried out by the Consortium as well as as from all the group negotiations that the Consortium has undertaken with other consortia for access to the registration dossiers of the other