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To all pre-registrants of Zinc related substances included in our portfolio,

Pre-SIEFs, SIEFs and Zinc Consortium

For each of the substances declared in the scope of work of the Zinc Consortium, the Consortium’s Secretariat is prepared to:

  1. Ease the contacts of the pre-SIEF members debating on the sameness of the substance.
  1. Undertake further the obligations of “Lead Registrant” and to act as the “SIEF Formation Facilitator” for the purposes of preparing and submitting the Registration Dossier, and where agreed the Chemical Safety Report (CSR), pursuant to REACH Article 11.

The Zinc Consortium was formed on 1 July 2007 for the sole purpose of assisting industry to comply with REACH.  It is an initiative of the International Zinc Association. The Consortium is comprised of the major EU manufacturers, major non-EU manufacturers, EU importers and traders, and their respective Affiliates.

The current 64 members of the Zinc Consortium (~150 legal entities) are focusing on generating and compiling necessary data for 20-25 Registration Dossiers. The Zinc Consortium has already dedicated substantial financial and personnel resources to this effort, and is advancing well in this respect.  Its members are committed to achieving submission of the Registration Dossier for all substances in the scope of work of this consortium before the first registration deadline of 1 December 2010.

The Consortium is undertaking to compile and assess all relevant existing studies and data necessary to prepare the corresponding Registration Dossiers. We will, as SIEF facilitator, collect information from the SIEF members as well as from sources outside the SIEF.

The Zinc Consortium has already conducted thorough data gap analyses, and is working to generate data to fill the gaps where appropriate. We are also working:

  • to translate all available information from former R.A.’s in IUCLID V format
  • to develop read-across approaches,
  • to develop hazard classification and labelling proposals,
  • to identify and evaluate downstream uses (and exposure scenarios),
  • to prepare the CSRs.  

The International Zinc Association (IZA) and its staff is contractually providing human resources and administrative support to the Zinc Consortium to coordinate these efforts.  Finally, the Consortium Secretariat is well versed in the SIEF obligations, and has been developing strategies and systems to manage the SIEF process.

Access to the Registration Dossier

For each of the substances declared in the scope of work of the Zinc Consortium, the Consortium, acting as secretariat of the SIEF, will ensure that all SIEF members intending to register under REACH have timely access to the Registration Dossier for that substance to enable them to register with ECHA by the earliest deadline.  In complying with REACH, we are seeking to balance sound science with responsible resource management.  We are committed to make available access to the Registration Dossier on fair, reasonable and non-discriminatory terms.  Interested companies will have two basic options to obtain the necessary access to information:

  • Companies that plan to register in the highest tonnage band and/or companies wishing to provide resources and expertise to contribute to the development of the Registration Dossier are encouraged to join the Consortium. This will provide companies full access to all information and data developed by the Consortium. It is expected that joining the Consortium will be the most cost effective option for the active participants and companies in the higher tonnage bands.
  • SIEF members that do not wish to join the Consortium will be able to obtain the Registration Dossier via a Letter of Access.  The Consortium is currently assessing the likely cost for access of companies intending to register that substance and will be established on a fair, reasonable and non-discriminatory basis to include all of the costs (including administrative and scientific) associated with the preparation of the necessary information.

Next steps

The first task is to move ahead with the Pre-SIEF activity i.e. to agree “sameness of substance”.  You will soon receive, or you already received an e-mail, with a link to a brief Pre-SIEF Questionnaire for you to complete and submit.

After evaluation of the Questionnaire response, the Consortium’s secretariat will then facilitate:

  1. The grouping together of all those pre-registrants that consider they do have the same substance, and they will enter into the SIEF for that substance.
  2. The grouping together of those pre-registrants that consider they do not have the same substance, for further discussion and potential entry into  sub-SIEFs or another SIEF.

The Consortium’s secretariat will also contact you again shortly with more details about:

  • the option to join the Consortium
  • the option to not join the Consortium, remain in the SIEF and fulfil your REACH Registration obligations by means of a letter of Access to the Registration Dossier on faire, reasonable and non-discriminatory terms

 

With Kind regards,           
                                                                  The Zinc Consortium secretariat

 

Disclaimer: The Zinc Consortium and IZA do not accept any liability whatsoever with regard to the content, accuracy or use of information contained is this document. The information it contains does not constitute any legal advice.

 

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