CETS has completed the consultation process and submitted its position on the SEAC Draft Opinion concerning the proposed restriction of certain Chromium(VI) oxides, oxyacids and salts.
CETS has finalised and submitted its response to the SEAC Draft Opinion consultation on the proposed restriction of certain Chromium(VI) oxides, oxyacids and salts.
The submission highlights the need for a proportionate, technically workable and harmonised regulatory framework that reflects the realities of the European surface treatment sector. Key issues addressed include technical feasibility, realistic transition periods, monitoring and enforceability, availability of alternatives and most of all the evaluation of value-chain impacts reflecting the need to avoid disruption of critical industrial capabilities.
The submitted short version reflects the consultation format, while the extended version provides the broader analysis developed during the preparation of the CETS position.
READ MORE: PDF – short version (uploaded on the ECHA website)
READ MORE: PDF – long version
The document sets out the views of the European surface treatment sector on the proposed restriction options, with particular attention to electroplating on plastic substrates, electroplating on metal substrates and other surface-treatment applications. CETS supports effective protection of workers and the environment from Chromium(VI) risks, but stresses that any regulatory measure must be proportionate, technically feasible, monitorable, enforceable and coherent with existing EU regulatory frameworks.
The submission highlights that many affected operators are job platers or specialised surface-treatment service providers working under customer, OEM, Tier I or Tier II specifications. For this reason, the socio-economic impact cannot be assessed only at the level of the direct Chromium(VI) user. The document calls for a broader value-chain assessment, including downstream manufacturing, repair and maintenance activities, spare-parts availability, customer qualification, strategic autonomy and security of supply.
CETS also addresses the availability and feasibility of alternatives, stressing that substitution cannot be assessed at broad use-category level only. Alternatives must be evaluated use by use, taking into account technical performance, industrial scale, customer approval, qualification requirements, economic viability and the risk of regrettable substitution.
A central part of the position concerns risk management measures, monitoring and enforceability. CETS underlines that implementation requires harmonised EU rules for measurement and compliance demonstration, clear treatment of respiratory protective equipment, and sufficient capacity from suppliers, laboratories and competent authorities.
The document also comments on costs, benefits and proportionality, noting that the assessment should include downstream impacts and should distinguish modelled statistical benefits from directly observable outcomes. CETS therefore calls for a workable and harmonised EU framework, with appropriate safeguard mechanisms where no technically and economically feasible alternative or compliance route has been demonstrated.