Representatives of the European surface association CETS visited the European Chemicals Agency ECHA in Helsinki in mid-November 2023. The reason for this was the mandate recently issued by the EU Commission 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).
The ECHA was represented by three persons from the Risk Management Unit who are important for the restriction and who should transfer the experience from the authorizations in order to avoid known problems. CETS was represented by Jaakko Kapanen, Vice-President of CETS, Dr. Markus Dahlhaus, Plating on Plastics Association (POP) FGK, and Dr. Malte-Matthias Zimmer, President of CETS and ZVO Head of Environmental and Chemicals Policy. The discussion took place in a very open and friendly environment. Many aspects of the upcoming challenge were viewed similarly.
ECHA will now carry out initial preliminary work on a proposal, which will lead to a "call for evidence" (public consultation of the EU Commission). The CETS' offer to be available at any time to discuss open questions was received positively. The participants agreed that this task offers great potential for improvement for authorities and industry. They also agreed that an analysis of the causes of the exclusive failure of the authorization approach for chromium trioxide is necessary. Neither side saw a fundamental problem with the authorization process or the ECHA's procedures. The CETS Executive Committee will continue to monitor the issue and follow it as closely as possible.