17 Nov 2023

The European Chemicals Agency (ECHA) has received a directive from the European Commission to formulate a restriction proposal under the requirements of Annex XV of the REACH Regulation, targeting at least two Chromium (VI) substances. The proposal is expected to be submitted by October 4, 2024, as specified in the Commission’s directive, accessible in full through the provided link: Link to Mandate Document

Chromium (VI) substances, outlined in 11 sections (16-22 and 28-31) within the EU-REACH Authorization list (Annex XIV), are categorized as cancer-causing (1A or 1B), posing a risk to both workers and the general population when exposed to the environment.

The proposed restriction will predominantly encompass the following two Cr (VI) substances:

Chromium trioxide (CrO3) – Annex XIV section 16:This specific Cr (VI) substance is responsible for most applications requiring authorization.

Chromic acid (H2Cr2O4) – Annex XIV entry 17: As a group of acids produced from chromium trioxide, it is imperative to include them in the scope of the restriction proposal.

One of the primary applications of these substances is in electroplating, a common surface-finishing process for coating materials.


The European Commission has received numerous authorization applications for the use of Cr (VI) substances listed in Annex XIV, overwhelming the Risk Assessment Committee’s (RAC) capacity. This situation undermines one of the key objectives of the authorization provisions, which is the gradual replacement of such substances with economically and technically viable alternatives.

Commission’s Directive:

As part of the restriction proposal, the Commission has instructed ECHA to conduct a brief analysis of alternative availability and assess the potential risk of replacing other chromium (VI) substances. If deemed necessary, an expansion of the mandate is possible. The standard REACH restriction process, involving assessment by the RAC and SEAC, will follow the preparation of the proposal. ECHA will incorporate insights from processing authorization applications for these substances in the proposal’s preparation.

Upon the Commission’s adoption of the restriction, the substances within the specified scope will be removed from the Authorization list, marking a significant milestone under EU-REACH.

ComplianceXL, drawing on its extensive regulatory expertise, stands ready to assist companies affected by the impending restrictions on specific Chromium VI substances proposed by the European Chemicals Agency (ECHA). As ECHA prepares to submit the restriction proposal by October 4, 2024, under Annex XV of the REACH Regulation, businesses involved in the use of Chromium trioxide (CrO3) and Chromic acid (H2Cr2O4) are urged to stay informed and take proactive measures.

Our compliance management services at ComplianceXL are well-equipped to support companies in efficiently navigating through the regulatory landscape associated with these proposed restrictions.

We offer tailored solutions to facilitate risk assessments, compliance management, and the generation of accurate and timely reports. By leveraging over two decades of regulatory experience, ComplianceXL ensures that organizations are well-prepared to address the challenges posed by evolving regulatory requirements.