The European Chemicals Agency (ECHA) has listed Chromic Acid as an SVHC (Substances of Very High Concern). It is therefore necessary to check whether there is a duty of notification for products according to article 33 of Directive 1907/2006/EC. (See our information sheet WI REACH 006).
The sunset date has been set at 21 September 2017, after this date authorisation will be necessary to use it.
Authorisation is being sought by the major importers and users within a SIEF (Substance Information Exchange Forum). Under the name of CTAC (Chromium Trioxide Authorisation Consortium). Their work is expected to be completed during 2015.
According to Article 56 of the REACH regulations, the first actor in a supply chain can apply for authorisation with all downstream users. The consortium will make use of this fact and apply for an authorisation to cover all functional and decorative chromium uses where alternatives do not currently exist.
However for most decorative applications Trivalent Chrome is considered to be a working alternative and it will be illegal to use Hexavalent Bright Chrome for that purpose after the "sunset day".
There is currently no working alternative for Hard Chrome plating which will therefore be allowable as long as the Chromic acid is sourced from an authorised supply chain.
The REACH regulations do not allow infinite authorisation and request regular applications from the original consortium to maintain the authorisation, proving each time that viable alternatives are not available . If a Trivalent Hard Chrome plating solution becomes available, then the authorisation to use Hexavalent Chrome for that application would be withdrawn.
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