On April 29, 2025, the European Chemicals Agency (ECHA) announced a proposal to restrict the use of hexavalent chromium (Cr(VI)) substances within the European Union. This measure aims to protect human health and the environment from the carcinogenic risks associated with these substances.

Background

Cr(VI) compounds are widely used in industries such as electroplating, surface treatment, aviation, and defense. Due to their carcinogenic nature, the EU has classified them as Substances of Very High Concern (SVHC) and requires authorization for their use. However, the number of authorization applications has far exceeded expectations, posing challenges for regulatory bodies and businesses. Consequently, the European Commission has requested ECHA to prepare a restriction report, considering the transfer of these substances from REACH Annex XIV (Authorisation List) to Annex XVII (Restrictions List).

Details of the Restriction Proposal

1. Scope of Substances and Applications

Substances: The restriction targets include chromic anhydride, chromic acid, dichromate, and their salts, as well as potential "regrettable substitutes" like barium sulfate.

Applications: According to the proposal, the use of most Cr(VI) substances will be prohibited, except in areas where they meet worker exposure limits and environmental emission standards, such as:

a) Electroplating (on plastic/metal substrates)

b) Mixture preparation

c) Surface treatment and functional additives

d) Primer and other paste production

2. Set Limits

Worker Exposure Limits: Different exposure limits are set for various categories, ranging from 0.1 µg Cr(VI)/m³ to 5 µg Cr(VI)/m³ over an 8-hour time-weighted average.

Environmental Emission Limits: Limits range from 0.025 kg Cr(VI)/year to 2.5 kg Cr(VI)/year for emissions to air and water.

3. Transition Period

Unified Transition Period: An 18-month transition period is proposed for all restriction options and usage categories, allowing businesses sufficient time to adapt to the new restrictions. This relatively short period is designed to encourage risk control over the development of alternative solutions.

Options in the Restriction Proposal

The proposal evaluates three different restriction options (RO1, RO2, RO3), varying in worker exposure and environmental emission limits:

RO1 (Least Stringent Option):

Worker Exposure Limit: 5 µg Cr(VI)/m³ for most categories, but 1 µg Cr(VI)/m³ for plastic substrate electroplating and certain functional additives/process aids.

Environmental Emission Limit: 2.5 kg Cr(VI)/year to air, 15 kg Cr(VI)/year to water.

Expected Impact: RO1 has relatively low compliance costs and minimal economic impact on businesses but offers limited health benefits.

RO2 (Moderately Stringent Option):

Worker Exposure Limit: Range between 0.5 µg Cr(VI)/m³ and 1 µg Cr(VI)/m³.

Environmental Emission Limit: 0.25 kg Cr(VI)/year to air, 1.5 kg Cr(VI)/year to water.

Expected Impact: RO2 strikes a balance between health protection and economic costs, with most businesses expected to comply by investing in risk control measures.

RO3 (Most Stringent Option):

Worker Exposure Limit: Range between 0.1 µg Cr(VI)/m³ and 0.5 µg Cr(VI)/m³.

Environmental Emission Limit: 0.025 kg Cr(VI)/year to air, 0.15 kg Cr(VI)/year to water.

Expected Impact: Although RO3 greatly reduces health risks, the compliance costs are very high, likely causing many businesses to cease operations or exit the EU market, hence considered disproportionate.

In summary, the proposal aims to reduce the risks associated with Cr(VI) substances by setting scientific limits while considering the compliance capabilities and economic impacts on businesses. By comparing different options, the proposal suggests RO1 and RO2 as proportionate restriction measures to balance health protection with economic activity.

ECHA estimates that the new regulation could reduce environmental emissions of Cr(VI) by 17 tons annually. Over the next 20 years, the total benefits are expected to range from 331 million to 1.07 billion euros, with societal costs potentially between 314 million and 3.23 billion euros, including costs for factory retrofitting, alternative development, and industry relocation. 

Starting June 18, 2025, stakeholders can participate in a six-month public consultation, and ECHA plans to host online briefings to assist the public in submitting scientific evidence. ECHA's Committee for Risk Assessment and Committee for Socio-economic Analysis will review the proposal and public comments, with the final decision on implementation made jointly by the European Commission and the 27 member states.

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