Two Months to REACH Restriction on certain Chromium (VI) Substances – Time to Prepare
On 11 April 2025, ECHA will submit the restriction proposal for certain chromium (VI) substances, marking a key step in the REACH regulatory process. Companies, industries and supply chains using Cr(VI) substances must act now to prepare for the upcoming public consultation.
The current list of expected substances includes the following:
- Chromium trioxide
- Chromic acid
- Sodium dichromate
- Potassium dichromate
- Ammonium dichromate
- Potassium chromate
- Sodium chromate
- Dichromium tris(chromate)
- Strontium chromate
- Potassium hydroxyocta-oxodizincate-dichromate
- Pentazinc chromate octahydroxide
- Barium chromate
*However, the final list of substances may still deviate from those listed above.
What’s Happening?
ECHA was tasked with developing several restriction options to effectively control the risks posed by these substances while encouraging the substitution with safer alternatives. The submission of the restriction proposal on 11 April 2025 will conclude Phase 1 of the process.
Within 30 days of the submission, ECHA’s Risk Assessment (RAC) and Socio-economic Analysis (SEAC) committees will assess whether the restriction dossier meets REACH requirements. If it does, a six-month public consultation begins – an important opportunity for industry to provide input, propose derogations, and help shape the final outcome.
The restriction proposal may include derogations with different transitional periods, depending on:
i) Risk levels associated with specific uses,
ii) Socio-economic impacts on businesses and supply chains, and
iii) Availability of alternatives.
If a derogation is not proposed by the Dossier Submitter, it is up to affected companies to provide a well-supported risk and socio-economic justification during the consultation.
Key Considerations for Businesses
Regulatory Uncertainty – The restriction will impact companies using Cr(VI) substances across various supply chains. Now is the time to assess your compliance strategy to avoid disruptions.
Potential Derogations – If your company relies on Cr(VI) substances, it is essential to submit robust justifications to secure derogations.
How to Prepare
Assess your supply chain – Understand where Cr(VI) substances are used and evaluate potential impacts.
Engage early – Your input during the public consultation can help shape the final regulation.
Prepare comments and justifications – A strong case can be decisive in securing a derogation.
It is important to note that this is the only opportunity to influence the outcome of the restriction, so now is the time to act and be active.
How REACHLaw Can Support You
Our CASE Team provides expert guidance to help businesses navigate this evolving regulation and advocate for their interests:
✔ Derogation support – Assisting with risk, alternatives and socio-economic justifications.
✔ Socio-economic impact assessments – Evaluating business and supply chain effects.
✔ Policy support – Helping companies engage effectively in the regulatory process.
With just two months remaining, companies should act now to ensure they are prepared.
For expert advice, get in touch with us at CASE@reachlaw.fi