Chromium VI: European Commission Q&A updated

The European Commission updated two Q&A documents on chromium VI (Cr VI) in December 2025. In particular, the following documents have been updated:

• APPLICATIONS FOR AUTHORISATION FOR USES OF CR(VI) SUBSTANCES IN FUNCTIONAL CHROME PLATING WITH DECORATIVE CHARACTER OR IN PLATING WITH DECORATIVE PURPOSE ONLY, document providing specific guidance for companies using the substance for decorative chrome plating uses (December 2025 version 2 replaces August 2024 version 1);
• TOWARDS A RESTRICTION OF CR(VI) SUBSTANCES UNDER REACH, document clarifying steps towards the introduction of a horizontal restriction on Cr VI compounds (version 4 of December 2025 replaces version 3 of August 2025)

These documents confirm an acceleration towards replacement, with more stringent measures for decorative uses and a restriction that could come into force by the end of 2027-beginning of 2028.

Let's see in detail the changes made to the documents:

1. Q&A chrome for decorative use

The document outlines the evolution of the decision-making process for REACH authorisations relating to decorative uses of Cr VI, which are characterised by greater difficulties in consensus in the REACH Committee than purely functional uses. The Commission has introduced additional measures to push towards substitution, taking into account the time elapsed since the sunset date of Annex XIV REACH and the strategies of each applicant, ensuring a case-by-case approach with equal treatment. Below is a summary of the paragraphs of the document, highlighting the most significant changes compared to the previous version:

Q#1 clarifies how the discussions in the REACH Committee have shown little propensity to grant authorizations for decorative uses (pure decorative or functional character with decorative character), leading the Commission to impose extra measures to speed up decisions and encourage substitution. These measures are substantiated by the recitals of the decisions and are tailored to address the specific characteristics of each ECHA application and opinion.

Q#2 clarifies that for applications with a review period recommended by SEAC beyond 1 July 2030 (2028 in the previous version of the Q&A document), the Commission imposes significant reductions in Cr VI volumes compared to those at the date of submission of the application (indicatively at least 50%, with a review period otherwise shortened to July 2030). Applicants are encouraged to include annual percentage reduction plans (not mandatory but useful), to be reflected in the decision-making conditions and review reports.

Q#3 outlines the case of the Chemservice application (CTACSub 1) for chromium trioxide in functional chrome plating with a decorative character (use 3) and related formulation of mixtures. After the consortium submitted its application for authorisation, the Commission asked for a substitution plan, following judgment T-837/16. In July 2021, SEAC deemed this plan not credible. Currently, no decision has been made regarding this particular application, so downstream users may continue using the substance under the transitional arrangements outlined in Article 56(1)(d) of REACH.

2. Q&A “from authorization to restriction”

The document outlines steps towards the transition of chromium VI compounds from the authorisation regime to the restriction regime.

The main changes made by version 4 (compared to version 3) are highlighted below:

• Restriction timeline (Q#3): in the previous version, 2027 was indicated as the possible date of entry into force of the restriction on chromium VI compounds, now this deadline is slightly postponed by indicating a generic "between the end of 2027 and the beginning of 2028";
  
  
• Alignment with OSH/IED legislation (Q#8): V3 merely clarified that the restriction would come into effect "without prejudice" to Industrial Emissions (IED) and Occupational Security (OSH) regulations. V4 instead adds the commitment to "align the REACH limit values with the OSH OELs" (with justified deviations). This strengthens regulatory consistency by facilitating integrated enforcement: companies with OSH monitoring can reuse data to argue compliance with the REACH restriction, reducing duplication and multi-regulatory compliance costs;
  
  
• Procedural clarifications on the application of the restriction (Q#6): in the new version it is clarified that the application of the restriction will probably take place with a transition of 18 months (e.g. for compliance ECHA proposal);

Q#7 represents one of the most critical points for the chemical industry, focusing on the management of authorization applications and review reports for Cr(VI) substances until the entry into force of the restriction.

In v3, the approach remained indicative:

• ECHA prioritized non-Cr(VI) applications over Cr(VI) applications, and among the latter, it favored new users over other applications or review reports.
• The Commission put forward a proposal to consult with the REACH Committee regarding an extension of the deadlines for review reports to a date beyond the entry into force of the restriction, with specific details yet to be determined. An amendment decision is under consideration, with discussion targeted for October 2025 and subsequent upload to the Comitology Register.
• Generic warning: low probability of finalization for new Cr(VI) submissions or review reports.

Specific commitments were missing, leaving uncertainty about timing and processes.

V4 transforms these intentions into implementing measures, with clarity on what will be processed, suspended and communicated:

• Rationalisation of pending and future applications: ECHA continues and completes only the application/review reports for which the opinion-making of the scientific committees has already begun, issuing the relevant opinions. On the other hand, it suspends all new Cr(VI) applications and Cr(VI) applications already sent but not yet processed (i.e. without an ECHA invoice sent). Interested practitioners will receive individual contacts for the status of their files.
• Detailed ECHA priorities: Maximum attention to non-Cr(VI) application/review reports and new uses or new Cr(VI) users not covered by existing authorisations or the transitional regime Art. 58(1)(c) REACH, to prevent disruption of market access.
• Formalized review reports extension: The Commission will adopt by Q1 2026 a Decision extending to January 1, 2029 all review reports for the next 3 years, modifying all authorizations in force. This measure shifts the horizon beyond the date of likely application of the restriction and will also be reflected in future authorisation decisions. The Commission will monitor progress for any further extensions through new acts.