ECHA Cr(VI) REACH restriction proposal available on 30 April 2025!

Do you need support with the public consultation on the Cr(VI) REACH restriction proposal?

Are you a user of Cr(VI) for chrome plating or surface treatments? Is the supply of chrome plated components or Cr(VI) based surface treatments critical for your value chain?

If yes, you will need to follow the ECHA Cr(VI) restriction very carefully to determine the impact on your business.

Background: ECHA received a mandate from the EU Commission in 2023 to prepare a restriction proposal specifically to address the risks from uses of Cr(VI) and to encourage substitution. The scope was initially limited to chromium trioxide and chromic acid but was later expanded to cover 12 Cr(VI) compounds. Once the restriction is adopted, the Commission intends to de-list these chemicals from the REACH authorisation list, i.e. use will no longer be subject to the authorisation requirement. This means that supply and use of these Cr(VI) compounds will depend on the scope of the restriction adopted and the timing of any derogations from the entry into force.

More information on the restriction is available on the ECHA website.

Public consultation on the ECHA Cr(VI) REACH restriction proposal will be launched in June 2025

On 30 April 2025, ECHA will make their restriction proposal available on their website in advance of the launch the public consultation on their proposed restriction option on 18 June 2025.

The public consultation will run for 6 months and is intended to collect input from all concerned stakeholders. The input can be on scientific or technical aspects, socio-economic impacts, implementation and enforceability and the scope of the proposed restriction.

What actions do you need to take?

Once the restriction proposal is published, it is essential to thoroughly examine its scope and assess the potential implications for your value chain. If your specific use case has not been addressed—or if you believe the proposed restriction does not fully account for its impact—you will need to submit comprehensive information detailing your application and the associated socio-economic consequences.

Timeliness is crucial!

The window for submitting information is short, and you should aim to provide detailed input as early as possible in the process. This is because the ECHA committee evaluations run concurrently with the public consultation, and the Socio-Economic Analysis Committee is required to deliver a draft opinion within 10 months of the consultation’s launch. 

It is critical to submit impactful comments – i.e information that will be taken into account in the opinion making process.

Apeiron-Team has the expertise and experience to assist you with your commenting strategy!

Reach out to our experts

Apeiron-Team can support you at every step in the process!

– from an analysis of the restriction options ECHA has proposed specifically for your business and value chain to assisting you submit impactful comments in the public consultation!

For more information, see our REACH restriction support services!

Reach out to our experts for more details at Info@apeiron-team.eu