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ECHA Board of Appeal: GruberChem GmbH, Germany

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Subject matter: A decision taken by the European Chemicals Agency (the ‘Agency’) pursuant to Article 20(2) of the REACH Regulation and Article 13(3) and (4) of Regulation (EC) No 340/2008 (the ‘Fee Regulation’)

Contested Decision: Decision SUB-D-2114565304-51-01/F of 7 September 2021 on the registration of disodium metasilicate

Remedy sought by the Appellant: In 2014, the Appellant registered  disodium metasilicate (EC No 229-912-9; the ‘Substance’) as a small or medium-sized enterprise (SME) by paying a reduced registration fee. On 18 July 2014, the Agency adopted a decision finding the registration complete and granting the Appellant a registration number for the substance.

On 3 December 2020, the Agency adopted a decision under Article 13 of the Fee Regulation, declaring that the Appellant was not eligible for the reduced fee and requiring it to pay the difference as well as an administrative charge.


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