On 27 September 2023, the Commission requested ECHA to assess the potential for regrettable substitution involving chromium trioxide and chromic acids, substances noted under entries 16 and 17 of Annex XIV to REACH. This assessment was crucial in determining whether the scope of restrictions should be broadened to prevent substituting these substances with other similarly hazardous chromium(VI) compounds.
ECHA's Findings and Revised Mandate
ECHA’s preliminary analysis revealed a widespread use of several chromium(VI) substances that could potentially circumvent the proposed restrictions through substitution. These findings prompted the Commission to amend its initial mandate. Now, ECHA is tasked to include additional substances, specifically those listed in entries 18 to 22 and 28 to 31, and to consider including non-listed substances like barium chromate, which pose similar risks.
Details of the Expanded Scope
The expanded scope of the dossier now encompasses a wider array of chromium(VI) substances, including:
- Sodium dichromate
- Potassium dichromate (both in entries 19 and 21)
- Ammonium dichromate
- Sodium chromate
- Dichromium tris(chromate)
- Strontium chromate
- Potassium hydroxyocta-oxodizincate-dichromate
- Pentazinc chromate octahydroxide
These substances are primarily used in various industrial processes and could potentially replace the initially targeted substances, thereby continuing to pose significant health and environmental risks.
Implementation and Timeline
In response to the expanded scope, the deadline for completing the Annex XV restriction dossier has been extended from 12 to 18 months, with the final submission expected by 11 April 2025. ECHA will conduct a second call for evidence in June 2024 to gather more comprehensive data on these substances, including their use in industrial applications and potential alternatives. A webinar scheduled for 6 June 2024 will discuss the findings from the first call for evidence and outline the scope of additional data required.
