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GROUP MEETINGS WITH PRE-REGISTRANTS UNDER REACH

Agenda. WelcomePurpose of the meetingSequence of the meetingCost elementsSIEF functioningData sharingCLP. Purpose of the meeting. Provide a common platform to member registrants, Chemexcil and OR representatives to discuss future course of actions.Give a brief picture of processes after pre-

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GROUP MEETINGS WITH PRE-REGISTRANTS UNDER REACH

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    1. GROUP MEETINGS WITH PRE-REGISTRANTS UNDER REACH 21st / 22nd Jan 2010

    2. Agenda Welcome Purpose of the meeting Sequence of the meeting Cost elements SIEF functioning Data sharing CLP

    3. Purpose of the meeting Provide a common platform to member registrants, Chemexcil and OR representatives to discuss future course of actions. Give a brief picture of processes after pre-registration. Assess the real situation of members desirous of going ahead and those who intend to drop out

    4. Purpose of the meeting Discuss group specific issues and action plan for the future Take concrete decisions for next steps. Collect data for taking up assistance issues with the Govt. Address issues raised by members as well as OR’s

    5. Sequence of the meeting General presentations by Dr Wakankar and OR representatives Segregate into class-wise groups for more specific discussions. Fill in questionnaires

    6. Cost elements Pre-registration costs 80 Euros / substance per legal entity. Registration costs (i) ECHA registration fees (SME & tonnage related) (ii) OR annual fees (100 / 300 Euros) (iii) OR travelling / lodging costs (actuals ?) (iv) Data costs (?) (tonnage related) (v) Lead Registrant costs (?) (hourly rate?) (vi) IUCLID data entry costs (?) (to be decided by OR / Chemexcil) (vii) Post Registration OR fees (?) (to be decided by OR / Chemexcil)

    7. ECHA fees – MSME status

    8. Steps to take Define your Organizational set up Define if it autonomous, partner ship etc Define holding or voting rights Define turnover Define manpower as AWU (Annual Work Units) Determine your MSME status. Document it in a certified manner.

    9. OR Annual fees Decided a figure of 100 Euros /year/substance/legal entity till the year before actual registration. 300 Euros /year/substance/legal entity in the year of registration. Covers charges for annual services provided by OR. Covers risks

    10. Data costs Data costs will differ from substance to substance based on tonnage band requirements, quality of data, pre-formed consortia’s. Cost sharing principles. Data acceptability.

    11. Data costs

    12. LR costs Lead Registrants are chosen from the SIEF members. Any SIEF member can offer himself as LR. LR’s can charge remaining SIEF members for the services they provide. They will be doing all the spade work, communicate with other members, file registration on behalf of members and so on. Convene the whole SIEF proceedings Likely to charge on hourly basis. ( e.g. 100Euros/hour)

    13. IUCLID costs Data has to be filled into IUCLID. Who will fill the data? What about confidential data? Training to members in case they want to fill their own confidential data. Costs of filling data into IUCLID and scope covered?

    14. Post registration OR fees OR is responsible for tonnages that have been registered. They will be responsible for any violation. They will be involved in SIEF for subsequent cost adjustments Will have role even after registration is completed Cost of providing these services after registration?

    15. CLP Different countries had different norms of classification and labelling. This was resulting in confusion and non-compliance. UN Orange Book is the bible for transport labelling Purple Book defines the new GHS system

    17. GHS - Purpose

    19. Concrete steps required Decide how far you want to go ahead. Recheck your submissions, checks exemptions or reduced obligations Agreement with OR Export details to your OR Various payments CL&P MSDS Use profile.

    20. Concrete steps required Reply to all mails from OR in a timely manner Raise doubts, issues with them or Chemexcil Remember even Dormant players have to take some actions Help Chemexcil to take up matters with GOI

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