For the continued use of Cr(VI) as of 21st of September 2017, a Cr(VI) authorisation is required or a decision on an application for authorisation needs to be pending. For this reason several users have filed over the past years an application for authorisation, either for their own use of for a group of users. While several of the individual applications have been granted, some group applications had to wait a very long time for a decision.
CTAC was one of the group authorisation dossiers which have been submitted by importers and formulators of Cr(VI) on behalf of a very large group of downstream users and had to wait for a very long tile for a decision. The scope of this application is broad and covers 6 uses of Cr(VI): (1) formulation, (2) functional plating, (3) functional plating with decorative aspect, (4) surface treatment aeronautics and space, (5) surface treatment and (6) passiviation of tin plated steel.
While the application was already submitted in May 2015, only on December 18th 2020, a partial decision on the application was published. This decision covers the uses 1,2,4,5 and 6. For the downstream user of Cr(VI) in these uses, there is an end to a long period of business uncertainty. For use 3 no decision has been reached yet. The decision grants authorisation for the uses 1,2,4,5,6 for a limited amount of time till September 2024.
Why did it take so long to take a decision on the upstream dossier? According to the EU parliament, the CTAC dossier presents many uncertainties with regards to the available alternatives, but also regarding the emission to and exposure of workers and the general population. These uncertainties have resulted in negative feedback from NGO’s and Member States further delaying the decision making.
The same deficiencies are the cause of the short review period for these uses. Additionally, the downstream users have various additional requirements listed in the decision.
The downstream user for Use 3 is still in the same uncertain position as before. There is no decision yet. Several downstream users have for this reason opted to apply for their own authorisation. This strategy has been proven successful for several major player in the sanitary sector.
The downstream users for the other uses first of all need to comply with the conditions set by the decision regarding alternatives assessment, minimization and monitoring. This can extend their use till 2024. But they also need to examine their position taking into account the review date of 2024. While possibly there will be a new joint application, the bar has raised and downstream users need to assess carefully if they want rely such a dossier or if they prefer to take their future in their own hands and apply for themselves.
To avoid this business uncertainty, several downstream users of CrVI have submitted individual applications for authorisation. Several of them have in the mean time been granted even for uses covered by the CTAC dossier.
The choice is of strategic importance. Apeiron-Team has supported in various cases downstream users in making this choice. In a workshop with the downstream user elements such as availability and quality of data, supply chain, required length of review period, business confidential data, common alternatives, costs, etc are taken into considerations.
The outcome of the strategy workshop allows the downstream user to make an informed decision regarding CrVI authorisation but also regarding development of alternatives.
See what strategy is possible for your company and contact Apeiron-Team for more information.
Apeiron-Team is currently forming homogeneous groups of downstream users in view of the preparation of strong applications for authorisation. Contact us for more information. Specifically we do this for conversion coating on galvanized steel and decorative and functional plating for the sanitary sector.
Have a look at the different stories we have available on authorisation or check-out our other REACH & CLP related services