Important information for downstream users of Chromium trioxide in the EEA supplied by Joint Stock Company Novotroitsk Plant of Chromium Compounds (NPCC)

REACHLaw as only representative applicant for Joint Stock Company Novotroitsk Plant of Chromium Compounds (NPCC) submitted an upstream application for authorisation for four uses of chromium trioxide by downstream users in its supply chain. The application was submitted before the latest application date and users in the NPCC supply chain have been covered by transitional arrangements since the sunset data for use of chromium trioxide in the EEA of 21.09.2017.

The Commission adopted and published the decision for three of four uses on 14.12.2020.

These uses covered by the decision are:
– Use 1: formulation
– Use 2: hard chrome plating
– Use 4: miscellaneous surface treatment

The review period granted for the three uses is 7 years meaning that the authorisation will expire on 21.09.2024.


The authorisation decision impose a number of conditions on both REACHLaw as authorisation holderand NPCC downstream users that must be complied with by deadlines specified in the decision. The first of these is that REACHLaw must update the exposure scenarios and provide them in amended safety data sheets to NPCC downstream users by 14.03.2021 for them to apply the operational conditions and risk management measures at their sites without undue delay. NPCC downstream users must take into implementation annual monitoring programs for workers exposure and environmental emissions of Chromium (VI). They must have finished the first measurements by 14.06.2021. Full details of all the conditions are given in the Commission decision given in the Annex.


As of 01.01.2021, REACHLaw as only representative for NPCC is now part of the CTACSub (CTACSubmission Consortium). CTACSub applicants received their authorisation decision on 18.12.2020 for five of the six uses they applied for. REACHLaw’s application is identical in scope for four of the six CTACSub uses. The decision texts for the three common uses between the applications are identical. CTACSub have prepared a series of Questions & answers for downstream users on 22.12.2020. NPCC downstream users are advised to follow the advice and instructions available from CTACSub relating to how to fulfil their obligations. Note that the dates given refer to the CTACSub decision and the dead-lines for REACHLaw decision are 4 days earlier as the decision was issued 4 days earlier.


Ramboll as technical consultant for CTACSub have organized a webinar on the 15.01.2021 to brief downstream users on the authorisation decisions. All concerned downstream users are advised to join the webinar.

To sign up to this webinar, please click here: 

The remaining use (Use 3: decorative chrome plating) applied for has not yet received its decision as the Commission requested the submission of a substitution plan prior taking a decision. The substitution plan was submitted on 10.09.2020 based on input from users in the NPCC and CTACSub supply chains. More information on how the substitution plan will be assessed is available on the ECHA website. Until a decision is taken, use is permitted via transitional arrangements.

REACHLaw acting as only representative authorisation holder for NPCC will file a review report. More information will be available in the webinar of the 15.01.2021.

You can access to the full details of all the conditions given in the Commission decision given in the Annex, via the following link: Info note for NPCC DUs 11112021_with annex (1)


If you are a downstream user of chromium trioxide in the NPCC supply chain and you intend to continue your use after September 2024, you will need an authorisation. The deadline to express interest in being part of the review application is 31.03.2021.

You can find the information Note and Sign-Up Commitment for the CTACSub2 Review Report on the JonesDay website via the link below:
If you have further questions please contact us via following email:
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