Information about the chromium trioxide authorization

The recent decision by the European Commission with regard to chromium authorization has resulted in the following change:

 

Although the EU Parliament has approved the draft, the European Commission is still to revise it. We do not anticipate there will be any major changes to the content of the draft. However, the indicated timeline will be extended. It can also be assumed that the review period as a whole will remain unaffected (September 21, 2024).

 

The next decision is likely to be made during the next REACH Committee meeting in mid-June. Although, on the whole, we can only speculate as to the outcome of this decision, we will nonetheless keep you up to date on developments and document all the necessary steps for you. In the meantime, should you have any questions, you can still reach us on +49 (0)89 78596-0 or by sending an email to chrome@kwalter.de.

Following the decision made by the REACH Committee on February 15, 2019, we are delighted to inform you of the following:

 

The European Commission has agreed to authorize the use of Cr(VI) for functional hard chrome plating (application 2, incl. “gravure”) for seven years. The authorization period begins on the sunset date of September 21, 2017 and is thus valid till September 21, 2024.

 

The following action plan (excerpt) has been drawn up in light of this decision:

April 1, 2019
Authorization decision notified to applicants (date estimated)
July 1, 2019
Authorization holders to draw up and distribute (as annexes to safety data sheets) specific exposure scenarios for representative processes, operations and individual tasks
July 1, 2019
Downstream users to notify uses to ECHA under Art. 66 REACH
October 1, 2019
Downstream users to finish first exposure measurement campaigns
April 1, 2020
Downstream users to notify data from exposure measurements and air and waste water monitoring to ECHA
October 1, 2020
Authorization holders to validate exposure scenarios with new data from exposure measurements and air / wastewater monitoring which they will have received from Downstream users via ECHA

For the time being, the three kinds of data highlighted here are relevant for you as a downstream user. We will provide you with all documents and information in good time to ensure all deadlines can be met.

 

If you have any questions, please do not hesitate to get in touch. To do so, please contact chrome@kwalter.de or  +49 89 785 96 0.

News and status on the REACH authorization of CrO3 by the EU

The authorization of CrO3 is immensely important for the gravure printing industry. With significant participation by the Heliograph company K.Walter as well as the ERA (European Rotogravure Association), leading European companies are driving this process in the EU. Here’s the current situation.

 

Together with the EU Member States, the EU Commission is still hard at work on the authorization of CrO3 for the gravure cylinder manufacturing industry (some other applications for special and individual applications have already been successfully adopted). The next decisions for gravure printing in the Functional Chrome Group are planned for June 2017. Whether something will actually be decided at this time is not certain. If not, the authorization decision could first be announced after the deadline for CrO3 use on September 21, 2017 (sunset date).

 

For all downstream users who are directly or indirectly supplied by the seven applicants and their distributors, such as K.Walter, nothing would change at first. They could continue usage until the final decision of the European Commission; further use of CrO3 by K.Walter customers is thus ensured.

 

If the authorization is definitively granted, downstream users, including K.Walter customers would have to report their use of chromium trioxide to the ECHA. This would have to happen within three months after a company received a delivery of CrO3 with the new safety data sheet, including authorization number. It would be obligatory for the company to comply with the conditions, which will be part of the authorization document.

 

To ensure that users in the gravure printing industry carry out the correct actions, K.Walter and the ERA will write a detailed manual describing all processes as well as all regulations that must be observed.

With the publication of the Official Journal of the European Union L108 chromium trioxide (as well as acids generated from it and their oligomers) beside other chromates is officially added to (the list in) Annex XIV of REACH Regulation (EC) No 1907/2006.

Thereby the deadlines of the authorization process have been fixed:

Latest application date: 21 March 2016
Sunset date: 21 September 2017

You may find the “COMMISSION REGULATION (EU) No 348/2013 (…) amending Annex XIV to Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)” under the following link:

https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2013:108:0001:0005:EN:PDF

An extract of the above mentioned regulation can be found here (PDF).

On 27 June 2012 took place the first “TC” Technical Committee meeting of the CTAC Chromium Trioxide Authorization Consortium took place in Brussels. The meeting focussed on the formal formation of the TC: The chairman of the TC and his deputy were elected, as well as the speakers of each “use group”.
The selection of a technical consultant company is in progress.
A meeting with ECHA will be arranged in autumn.

The kick-off- meeting of the Chromium Trioxide REACH Authorization Consortium took place in Brussels on 22 May 2012. Since ECHA (European Chemical Agency) recommended to list chromium trioxide in the REACH Annex XIV as a substance of high concern, the consortium has been formed: the goal of the consortium is to work out the necessary documents for the authorization process in order to secure the future use of chromium trioxide for industrial purposes. Altogether about 150 companies (manufacturers, importers and users of chromium trioxide, among them the aircraft industry) are members of the consortium. K. Walter represents the gravure industry in the consortium and will be supported by ERA and its staff. The Technical Committee as well as the different user sub groups, which are in charge with the technical research and collection of the necessary data for the authorization document, will now take up their work at the forthcoming meeting on 27 June. The authorization document will be compiled right in time to be available for the gravure industry when the authorization has to be finalised with ECHA (36 months after the listing in REACH Annex XIV which will be approximately by May 2016).

The largest manufacturers, importers and usres of chromium trioxide have founded a European Consortium whose goal is to achieve authorization for further use of chromium trioxide. K.Walter joined this association on March 8, 2012. In close cooperation with the ERA, K.Walter intends to represent the interest of the gravure printing industry in the best way possible.

 

 

Against the backdrop of a recommendation by the European Chemical Agency (ECHA) from December 2011, this commitment seems urgently needed. The ECHA recommendation calls for authorization of chromium trioxide under REACH. In gravure printing, chromium trioxide is used to produce hard chromium layers for printing cylinders. If the EU accedes to this recommendation, then almost certainly from the beginning of 2013, chromium trioxide will almost certainly be included in the REACH Annex XIV for generally forbidden substances.

  1. With inclusion in Annex XIV, marketing and use of this substance will be banned in the EU 39 months later, that is, in mid-2016.
  2. The only circumstances under which this prohibition would not apply would be upon user-specific authorization, i.e. after submission of a request to ECHA, who would have to grant permission.
  3. If companies do not obtain this authorization, they may no longer use chromium trioxide, regardless of the economic consequences for these companies.
  4. Authorization must be issued to at least one member in the supply chain.
  5. At the moment, there is no available industrial process that can make a surface that can substitute for a chromium surface.

Our opinion is that the gravure printing industry will need the chromium process and the associated production steps for many years to come. This position was also presented on March 7, 2012 by Christoph Gschossmann, CEO of K.Walter,  at the joint meeting of the ERA technical commissions in Dusseldorf. He also requested a statement from the ERA and its members. ERA members agreed that K.Walter represent the gravure printing industry in the consortium, in which all necessary papers, measurements and dossiers for the request for authorization from ECHA will be developed. By vote, it was decided to support K. Walter in the procurement and preparation of the necessary data for the dossier and the preparation of the proposals for the future airborn limits.

Our view is that the chromium-plating process in gravure printing is much more advanced and safe than in comparable industries in regard to environmental and work safety. There is a high probability of obtaining authorization if we describe the specific uses in gravure printing with the existing plant technology and work them into the authorization dossier.

K.Walter will take an active part in the authorization process on behalf of the entire gravure printing industry. This is the only way we can be sure of getting the latest information at all times and optimally protecting the interests of the gravure printing industry.

We will keep you up-to-date on all pertinent information in the helioscope newsletter (www.heliograph-holding.com)and at www.kwalter.de.

If you have questions on this very complex issue, don’t hesitate to contact our team of experts at chrome@kwalter.de.