Is the use of Cr(III) as alternative to Cr(VI) in chrome plating systems “regrettable substitution”?
Cr(III) plating systems are the most commonly proposed alternative to Cr(VI) plating systems in REACH authorisation applications submitted for chrome plating uses of chromium trioxide. While Cr(III) compounds are less hazardous than C(VI) compounds, Cr(III) plating systems may require the use of borates that are classified as toxic to reproduction (Repr. 1B). In addition, Cr(III) compounds may be manufactured from Cr(VI) starting materials meaning substitution potentially shifts the risk to workers upstream. This substitution strategy therefore may not reduce the risk to human health and would be “regrettable substitution”.
European Chemicals Agency is hosting a workshop on 10 October 2022 to discuss the broader implications of substituting plating systems that are based on Cr(VI) with those based on Cr(III).
REACHLaw will be following the developments closely and will keep our clients informed of the implications on their authorisation applications. Welcome to contact our REACH authorisation service team at Authorisation@reachlaw.fi for support on the applications process. For more information click here.