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Cr(VI) authorisation…What is the state of play? How to act as a downstream user?

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The story of a complex dossier

As of 21st of September 2017 the use of Cr(VI) is not allowed unless an authorisation for your use has been granted or a decision on an application for authorisation is pending. The latter is the case for several downstream users of Cr(VI). They depend on applications such as the one submitted by CTAC.

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. The scope of the 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.

Although submitted already in May 2015, to date still no final decision has been reached by the European Commission on whether or not to grant authorisation for the aforementioned uses. Even if decided in the near future, there is a still a big uncertainty on what would be the set review period for each of the uses. Authorised use till 2023, 2024, longer or shorter?

Why does 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.

What about the downstream user?

As downstream user of Cr(VI), but the same is true for other substances on Annex XIV of REACH, you have 2 options:

  • Sit back and continue to rely on your supplier and their authorisation dossier
  • Take your future in your own hands and submit your own authorisation dossier or in a limited group

 

To avoid this business uncertainty, several downstream users of Cr(VI) 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 authorisation but also regarding development of alternatives.

Relevant Apeiron Services

See what strategy is possible for your company and contact Apeiron-Team for more information.

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Posted by
Laetitia Six

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