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Current customer information

After a period of roughly four years, the EU Commission issued several positive authorisation decisions for uses of chromium trioxide in December 2020:

Use 1: Formulation

Use 2: Hard chrome plating

Use 4: Various surface treatments

An authorisation has been granted until 21 September 2024.

A DECISION IS STILL OUTSTANDING FOR USE 3, ‘DECORATIVE CHROME PLATING’.

You will be notified of the specific authorisation numbers for the applications via our product labels and our safety data sheets.

The use of substances subject to authorisation is tied to a number of conditions, which are listed below:

1.) After the authorisation is granted, article 66 of the REACH Regulation requires the ECHA to be notified by each and every downstream user within the first three months of receipt of the first supply (involving products with chromium trioxide).

At this juncture, we would pass on the recommendation from CTACsub, which is to notify the ECHA no later than three months after the authorisation is granted.

-          Accordingly, a notification using the ECHA reporting tool should be completed by approximately 18 March 2021. -

For details of the key functionalities that are required for the notification, please see the information provided in section 15 of our safety data sheets.

Further details of these key functionalities for the above-mentioned uses can also be found by consulting the Q&A at https://jonesdayreach.com/news/.

2.) Another important element of authorisation is the implementation of risk management measures that were drawn up by the applicants as part of the authorisation procedure. These can be viewed on the good practice sheets (GPS) available from the following link: jonesdayreach.com/substances/

Authorisation holders are expected to provide the exposure scenarios to supply chain stakeholders by mid-March: if additional risk management measures beyond those specified on the good practice sheets become necessary, we will share details of these measures within the supply chain.

3.) A further authorisation condition consists of programs for measuring workplace exposure levels as well as measurements of air and water emissions, to be implemented by downstream users. Initial measurement data must be provided by 14 June 2021. For implementation details, see the above-mentioned link to the CTACSub Q&A and to the GPS (we include the link as part of section 2).

4.) The results must be notified to the ECHA by 8 December 2021.

5.) These measurements must then be carried out on an annual basis.

A Q&A document prepared on the subject of chromium trioxide authorisation is available from the following link:

  https://jonesdayreach.com/news/

-          Please note: the dates specified in the Q&A refer to the authorisation for the CTACSub Consortium itself, while the dates specified in our correspondence refer to a separate consortium which has since become a member of CTACSub.

It is essential that you complete all of the above steps otherwise you will not be covered by the authorisation.