The Blog

Many of us had this date circled on our calendars. According to the official schedule, today marks the submission of the chromates restriction proposal under REACH. This milestone is often mistaken for the publication date – but in fact, today begins the 30 days conformity check process.

Starting now, ECHA’s committees – RAC (Risk Assessment Committee) and SEAC (Socio-Economic Analysis Committee) – will assess whether the submitted dossier conforms to REACH requirements set by REACH. If the dossier is deemed conformant, a public consultation will be launched.

So, when do the real next steps begin?

In practice, the time between submission and the launch of public consultation varies, depending on:

• Whether the dossier is found to be conformant on the first try
• Whether ECHA requests additional information from the submitter
• The overall complexity and completeness of the dossier

Based on past restriction proposals:

• If the dossier is conformant upon first submission:
  → Public consultation typically starts 2 to 3 months after submission.
  (This includes a 30-day conformity check, internal coordination, and translation.)
• If revisions are needed:
  → It may take 4 to 6 months or more before consultation begins, depending on how quickly the revised dossier is submitted and re-assessed.

Our forecast:

Assuming conformity at first submission, we expect the restriction proposal to be published by the end of April, with the public consultation kicking off in mid-June.

Why this matters

This restriction targets Cr(VI) substances, aiming to reduce health and environmental risks while promoting safer alternatives. The submission marks the start of the formal review process, which includes a six-month public consultation.

This upcoming consultation is the key opportunity for industry to influence the outcome – by providing feedback, supplying data, and requesting derogations based on risk, socio-economic impacts, and the availability of alternatives.