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Authorisation must not encourage substitution to unsuitable alternatives

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Apeiron-team writes to the EU Commission regarding Cr(VI) Authorisation

In March 2023, Apeiron-team wrote and provided a paper to DG GROW of the EU Commission which addressed the current shortcoming of the Authorisation process in relation to Cr(VI), namely, how the current evaluation of Authorisation applications is encouraging the substitution to unsuitable alternatives.

Within this paper, Apeiron-team argues that the overall risks of alternatives are not being appropriately assessed. As a consequence, this is leading to inappropriate conclusions that some alternatives, namely Cr(III) solutions with boric acid, are a suitable and safer alternative for Cr(VI), despite evidence demonstrating the contrary.

The consequence of this is that applicants of Cr(VI) authorisation are incentivised, through the attainment of longer review periods (i.e. 12 years), to substitute to non-safer, and unsuitable alternatives. This result is in stark contrast to the overall aim of REACH, which is intended to ensure a high level of protection of human health and the environment, whilst enhancing competitiveness and innovation.

In the paper written by Apeiron-team, the current approach for evaluating Authorisation applications is criticised with a series of justified arguments. The paper concludes with a number of constructive recommendations to the Commission, which Apeiron-team deems necessary to ensure substitution to suitable alternatives is encouraged.

The executive summary to this paper can be accessed here

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Are you affected by the Cr(VI) Authorisation process? Are you considering substituting to Cr(III)? Then the full paper is relevant for you.

Click on “Talk to our Experts” on the right-hand side or email to request a free copy of the position paper.

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