Key takeaway
What This Development Means
The EU’s proposed Chromium(VI) restriction replaces REACH authorisation with enforceable limits on exposure and emissions. With three policy options under review and implementation likely from 2028, stakeholders must prepare now to maintain compliance and protect workforce health.
How do RO1 and RO2 differ in the Chromium(VI) restriction proposal?
RO1 sets moderate worker exposure and environmental thresholds. RO2 includes stricter emission controls, offering greater protection to the general population. Both are more feasible than RO3 and will form the basis for final regulatory decision-making.
What actions should companies take now regarding the Chromium(VI) restriction?
Begin by auditing Chromium(VI) uses, reviewing exposure levels, and evaluating alternatives. Engage in the upcoming consultation and prepare for a transition to Annex XVII compliance ahead of the expected 2028 enforcement date.
Source basis: https://echa.europa.eu/completed-activities-on-restriction
The European Chemicals Agency (ECHA) has proposed a significant shift in EU chemicals policy by recommending the restriction of 13 Chromium(VI) substances under REACH Annex XVII. Announced on 11 April 2025, the proposal would replace existing authorisation obligations with strict exposure and emission limits by 2028. This change impacts the full manufacturing value chain, from surface treatment providers to aerospace primes and automotive suppliers.
Key Chromium(VI) Substances Targeted
The proposal targets substances such as chromium trioxide, sodium and potassium dichromate, strontium chromate, and barium chromate. These are used extensively in electroplating, corrosion-resistant coatings, and primers—particularly in aerospace, automotive, and industrial maintenance.
The grouping approach prevents companies from substituting one hazardous Cr(VI) substance for another, reinforcing the proposal’s goal to eliminate regrettable substitution.
Restriction Options: Balancing Protection And Feasibility
ECHA assessed three restriction options (RO1, RO2, RO3) with differing levels of stringency:
- RO1 introduces exposure limits aligned with scientific recommendations but with moderate emission controls. It is expected to be widely achievable by most firms.
- RO2 adds tighter environmental limits, offering greater general population protection while still technically feasible for many users.
- RO3, the most stringent, enforces extremely low workplace and environmental exposure levels to reduce lifetime cancer risk below 1 in a million. However, this option is considered economically disproportionate and impractical for the majority of operators.
Both RO1 and RO2 are likely to offer the best trade-off between health protection and industry viability. ECHA has prepared draft legal text for both, allowing policymakers to decide which path to pursue during the legislative phase.
What’s Next? Consultation And Decision-Making
The restriction proposal is currently under review by ECHA’s Risk Assessment (RAC) and Socio-Economic Analysis (SEAC) Committees. A public consultation is expected to follow in mid-2025, offering stakeholders a chance to comment on technical and economic impacts.
Final decisions will be made by the European Commission in coordination with Member States. If adopted, the restriction will take effect in 2028, with no grace period unless explicitly granted for critical uses.
Downstream users are urged to assess their compliance gaps early and participate in consultation rounds to influence feasible implementation.
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