General Assembly Meeting Thursday, May 5th 10:00 – 13:00

General Assembly Meeting - 2022

Highlights from the General Assembly Meeting

The 2022 General Assembly meeting which took place virtually on May 5th discussed general issues related to the smooth running of the consortium as well as possible threats emanating from ECHA/the Commission by way of potential Restrictions/Authorisation related to the use of several Mn substances within the EU amongst other things.

The meeting saw the following decisions taken

The GA agreed a on methodology to redistribute income from Non-EU REACH data sales. MARA’s assets in the form of study reports are being sold for the purposes of Non-EU regulatory compliance in the hope of sharing knowledge on the toxicity profile of Mn-based substances in view of a worldwide harmonising the classification. The GA agreed that if the entire industry use the same data – then industry will settle for the same classification.

MARA’s Office: The GA discussed the need of an actual office versus a virtual office from a financial standpoint. Considering that work was still effective during the pandemic lockdown, it was clear that a virtual office will reduce cost without affecting the quality of work carried out by the Consortium. To this end, the GA approved for MARA to seek advice from the French authorities on the possibility of a Not-for-profit organisation to be domicile virtually.

Harmonised Categorization of Slags across the EU: The GA approved a way to fund this special project. The project which considers the present regulatory constraints on the use or disposal of slags across the EU to be non-harmonised is aimed at creating a level playing field guided by a harmonised regulatory standpoint for all players within the EU. The project intends to use a robust socio-economic analysis and lobbying of the authorities to achieve its goes.

Mn Dossier update - CSR submitted Jointly

Manganese metal REACH dossier faced extensive updates during the year 2021. Following demands from ECHA and in order to understand post 2010 co-registrants use and exposure patterns an extensive survey was launched and a registration update was submitted on 21 September 2021 to align with this new/uptodate information - this submission was rejected with feedback from ECHA mainly focussing on unaccaptable Bioaccumulation waiver.

ECHA's concerns were addressed and the dossier re-submitted - this second submission was accepted by ECHA on 7 December 2021.


Furthermore, a proposal was made by some co-registrants for the Lead registrant to submitted a joint CSR. After examination of the proposal by the Manganese REACH Administration (MARA) Board it was considered more convenient for co-registrants if the CSR was formally included as part of the joint submission. Hence a further update was concluded on 8 December 2021.

We consider that the jointly submitted CSR covers the vast majority of common uses of manganese metal in the EU but registrants should check carefully to make sure that their own uses are covered. Registrants with niche uses may need to complete their own CSR to cover the said use.

The cost associated to all the above mentioned updates will be recalculated in the reimbursement model and a top-up invoice or credit note ( as the case may be) will be issued to all registrants.

We do not anticipate doing any more work on  the Mn metal dossier during over 2022 unless ECHA request further information. 

In case of questions on the CSR please contact


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