ECHA Opens Second Public Consultation on Chromium (VI) Restriction Impacting EU Manufacturers

The restriction targets widely used but hazardous compounds—like chromium trioxide and various chromates and dichromates—known for their high carcinogenic potential. The proposal, if enacted, will demand new operational and monitoring standards, with stakeholders urged to respond by 18 September 2025 for early consideration.

Background: Why Chromium (VI) Is Under Scrutiny

Chromium (VI) substances are recognised carcinogens linked to serious health risks through inhalation and environmental exposure. Despite existing authorisation controls, inconsistent application across Member States and significant processing delays have prompted ECHA to recommend a more enforceable, harmonised approach via restriction.

Currently used across sectors for corrosion protection, electroplating, and metal finishing, these compounds include chromium trioxide, sodium dichromate, and potassium chromate. ECHA’s concern also extends to potential regrettable substitution with similar toxic substances such as barium chromate.

Restriction Options and Compliance Thresholds

Two core regulatory options are proposed:

• Option A permits continued use if site emissions remain below 2.5 kg/year to air and 15 kg/year to water, with occupational exposure limits at 5 μg/m³ or 1 μg/m³ (8-hour TWA), depending on the use category.
• Option B imposes stricter limits—0.25 kg/year (air), 1.5 kg/year (water), and workplace exposure caps as low as 0.5 μg/m³.

The restriction would apply to substances ≥0.01% w/w in mixtures, covering all stoichiometries and hydration forms. A uniform 18-month transition period is proposed following adoption.

Who’s Affected and What Comes Next

Beyond manufacturers, the restriction could impact importers, downstream users, coating applicators, and the recycling sector. Companies will need to review monitoring practices, assess emissions, and potentially substitute materials—posing both cost implications and innovation opportunities.

The ECHA Committees for Risk Assessment (RAC) and Socio-Economic Analysis (SEAC) will finalise their opinions by mid-2026. Industry input during consultation will be critical to shaping the final regulatory design.