AfA Teams Winter Newsletter

AfA team’s Winter

REACHLaw’s Authorisation team (AfA team) has been working with many projects during this year and the schedule looks busy also for the upcoming winter. We are glad to be in contact to you through our newsletters.
The REACH Authorisation process now has new requirements for the submission of substitution plans when ”alternatives are considered to be generally available”.  These requirements originate from March 2019 when the General Court of the European Union annulled an authorisation for certain uses of lead chromates which Commission had already granted. It follows from the judgment that an authorisation may be granted if the applicant submits a substitution plan.
Substitution plans have been required for adequate control route but now since July 2019 also for the socio-economic route. Substitution plan is consisted of factors affecting substitution, timetable with milestones and monitoring. The “public version” of the substitution plan is part of the package on broad information on uses. As such, it will be published on ECHA’s website for the purpose of the public consultation on alternatives for each application for authorisation.
New substances to be listed to the Authorisation List are other important recent development. 11 new substances have been accepted to the Authorisation List. The new entries include substances used as polymer additives, functional fluids, crop protection, health care and coatings.  These new substances will need authorisation to be used after the sunset date. Figure below gives some insight which sectors will be affected.

We want to highlight in this newsletter the chrome plating and chromate coating sectors because they have been and will be in the future massively impacted by REACH Authorisation.  Our experts have recently published articles (in Finnish) in Kemia magazine ( and in Chemical Watch ( about chromates’ authorisation process. We also recently gave a webinar on “Are you a DU of Chromates covered by an upstream application?”. You can access the recording at

Learned Experiences

Based on our experience preparing chromium use applications in the past, we see that one of the challenges is related to how widely used chromates are by very different sectors. The challenge for the initial upstream applicants was how to collect the necessary information for the reports in the most efficient way given when the high number chromates of users (potentially 1000’s) and the number of sectors involved are high. These upstream applications therefore had “uncertainty” in terms of the representativeness of the information submitted for all sites covered and for many, this has delayed decision making for years.

Due to these delays, there is an ongoing flow of new and re-applications for authorisation for chromates being submitted by downstream users. More and more downstream users are organizing themselves to prepare individual or group applications to continue their uses.  The chrome platers have an additional worry in the future as lead metal is on the Candidate List for inclusion on the Authorisation List. Lead anodes are the most commonly used anodes in chrome plating both with CrIII and CrVI.
REACHLaw has increased the capacity of its AfA team to face the future challenges and workload. Our multidisciplinary team provides a range of services from preparing applications for authorisation, exemption analysis and scoping studies to technical advocacy for clients, just to mention some. Here is our AfA team:

Bernadette Quinn, Senior Authorisation Specialist / Head of Authorisation practice
Bernadette is the project manager for the authorisation team here at REACHLaw. She is an industrial chemist by training and has a PhD from Helsinki University of Technology in electrochemistry. Prior to joining REACHLaw, she worked for 10 years at ECHA.  She has extensive experience on REACH regulatory processes, preparing regulatory reports and guidance material.

Tero Koski, Senior Specialist / Socio-Economic Analysis
Tero is a Finnish-qualified economist with over 5 years’ experience of REACH, mostly Authorisation and SEAs. He is responsible for socio-economic analysis at REACHLaw and has prepared over 20 SEAs which 5 were related to chromates.

Eduardo Barreto Tejera, Senior Specialist / Chemical Safety Assessment
Eduardo holds two master’s degrees in Env. Sciences. His expertise relates to environmental fate and pathways of chemicals, hazard assessment of chemicals, and exposure assessment and risk characterisation of substances and mixtures in use applications.

Eva Marcon, Specialist / Analysis of Alternatives
Eva Marcon has a master’s degree in Organic Chemistry and she specializes in the Analysis of Alternatives (AoA). She has successfully developed several AoAs and substitution plans for diverse industry sectors.
Satu Ryytty, Specialist / Socio-Economic Analysis
Satu has a master’s degree in environmental economics from University of Helsinki. She has recently started working in Authorisation Team and is working with projects related to socio-economic analysis (SEA).

Contact Us 

You can find more info on our experts here and our services here. We will get back to you with timely topics in the future but if you have any questions related to substitution plans or related to authorisation process – please don’t hesitate to contact us.
With best regards,
AfA team

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