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CETS and ECHA in exchange on chromium trioxide

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Dr. Markus Dahlhaus (FGK), Dr. Malte Zimmer (CETS) & Jaakko Kapanen (CETS)

On November 13, 2023, representatives of CETS visited ECHA in Helsinki. The reason was the EU Commission’s recent mandate to ECHA to develop restriction options for chromium trioxide. The aim is to transfer the substance from Annex 14 of REACH (substances subject to authorization) to Annex 17 (restricted substances).

ECHA was represented by three representatives from the risk management department who were key to the restriction and who were supposed to transfer the experience gained from the authorization in order to be able to avoid the known problems with the authorization.

The CETS was represented by Jaakko Kapanen (Finland, Vice-President of the CETS), Dr. Markus Dahlhaus (Germany, plating on plastics association FGK) and Dr. Malte Zimmer (Germany, President of CETS).

The conversation came about based on an agreement with Dr. Sharon McGuinness, Executive Director of ECHA, from February 2023. It was agreed to exchange ideas on new, relevant topics.

The conversation took place in a very open and friendly environment. Many aspects of the challenge at hand were viewed very similarly. ECHA will now carry out initial preparatory work on a proposal, which will result in a call for evidence. The CETS’s offer to be quickly available at any time to discuss open issues was positively received. It was agreed that this task opens up great opportunities for improvement for authorities and industry. It was also agreed that a clear analysis of the causes of the exclusive failure of the authorization approach with chromium trioxide is necessary; Neither side saw a fundamental problem with the authorization process or with ECHA’s procedures. The CETS Presidium will continue to monitor the issue and accompany it as closely as possible.