REACH: ECHA Submits REACH Restriction Proposal for Chromium (VI) Substances

The European Chemicals Agency (ECHA) submitted its restriction proposal for certain chromium (VI) substances under REACH on April 11, 2025. This submission follows the expanded mandate issued by the European Commission on May 8, 2024 (Link). 
The restriction proposal targets several chromium (VI) substances, including those specified in entries 16-22 and 28-31 of the REACH Authorisation List, plus additional substances such as barium chromate (EC 233-660-5). The substances expected to be included are 

• Chromium trioxide
• Chromic acid
• Twelve additional CrVI compounds, including those listed in entries 16-22 and 28-31 of the REACH Authorisation List
• Barium chromate (EC number 233-660-5) over concerns of ¿regrettable substitution¿

The final list of substances may differ from this preliminary assessment.
Within 30 days of submission, ECHA's Risk Assessment Committee (RAC) and Socio-Economic Analysis Committee (SEAC) will assess whether the restriction dossier meets REACH requirements. If the dossier passes this conformity check, a six-month public consultation will commence, most likely in June 2025.
The restriction proposal may include different restriction options with potential derogations. These derogations may have varying transitional periods based on risk levels associated with specific uses, socio-economic impacts, and alternative availability. If ECHA does not propose a derogation for a particular use, affected companies must provide risk and socio-economic justifications during the consultation period.
This public consultation represents the primary opportunity for industry stakeholders to influence the final restriction. Companies using chromium (VI) substances should prepare by assessing their supply chains, planning consultation participation, and developing evidence-based justifications for uses where derogations may be necessary.
The submission represents the culmination of a regulatory process that began with the European Commission's initial mandate in September 2023. Companies that utilize chromium (VI) substances should monitor ECHA's website for the official publication of the restriction proposal and consultation announcement.