REACH restriction on chromium(VI) compounds: RAC and SEAC opinions published

The proposal to restrict hexavalent chromium compounds is proceeding through the institutional steps. Following the presentation of the proposal and an initial consultation, it is now time to review the opinions of ECHA's technical committees: RAC, on human health and environmental risk assessment, and SEAC, on socio-economic assessment.

The proposed restriction

Before summarising the two opinions, let's take a step back and briefly recall what the proposed restriction entails.

The proposal is applicable to 13 chromium VI compounds, most of which are currently listed in Annex XIV (authorisation). Should the restriction be approved, these compounds would migrate to Annex XVII (restrictions).

The proposed restriction does not apply to intermediates.

The proposal consists of a ban on the use of the 13 compounds, unless they are used for permitted applications and in compliance with specific occupational exposure limits (LVs) and environmental emission limit values (ELVs). The proposal presents three different restriction options (ROs), which differ precisely in terms of limit values, as shown below:

RAC opinion

ECHA's Committee for Risk Assessment has issued its opinion on the suitability of the proposal to control risks to workers and the general population through environmental exposure.

The opinion can be summarised in the following key points:

• RAC does not support the derogation currently granted for intermediates, clarifying that exposure to the substance could also occur during these uses. This would go against the original proposal and what is currently envisaged under the authorisation regime;
  
  
• For the protection of workers, RAC considers that the limit value should not exceed 0.1 μg/m³, effectively endorsing RO3, but proposing a value well below the current European OEL (5 μg/m³), which, according to RAC, should therefore be adapted to the proposed value. The proposal would therefore apply a single LV, without differentiation between the various use categories;
  
  
• For the protection of the general population exposed through the environment, RAC considers ELVs of 0.25 kg Cr(VI)/year in air and 0.15 kg Cr(VI)/year in water to be effective in reducing risk and technically achievable by most companies. According to RAC, these ELVs should be aligned with other European legislative frameworks, such as the revision of BATs (Best Available Techniques) under the IED (Industrial Emissions Directive);
  
  
• Considering that non-threshold genotoxic effects of chromium VI compounds cannot be excluded, RAC recommends ensuring that companies work to minimise exposure and emissions to values even below the LVs/ELVs;
  
  
• RAC proposes adding a condition to the restriction entry requiring monitoring measurements to be carried out when installations operate at a capacity level similar to the maximum capacity level reached in the last 12 months, in order to cover the maximum emissions and related exposures during the year. It also recommends that biomonitoring be considered common practice when assessing exposure to chromium VI compounds;
  
  
• RAC considers that the restriction should be accompanied by guidance, available before its entry into force, to support both obligated entities in complying with the requirements and national authorities in their enforcement activities. The guidance should clearly define the substances included in the scope, the six use categories and processes concerned, as well as the main technical and legal terms. It should also indicate good practices for identifying and applying operating conditions and risk management measures suitable for minimising exposure and complying with limit values to protect workers and the general population. Finally, the document should provide guidance on monitoring methods, including biomonitoring, reporting methods and the use of measurement data to demonstrate compliance. RAC also recommends referring to validated and harmonised standards and sampling and analytical methods, so as to ensure uniform control conditions across all Member States.

SEAC opinion (draft)

The draft opinion can be summarised in the following key points:

• SEAC confirms that action at EU level is needed to manage consistently the risks associated with the proposed hexavalent chromium compounds, so as to avoid differences between Member States that could lead to competitive imbalances and inconsistent levels of protection for workers and the general population.
  
  
• SEAC considers the proposed package of options to be broadly viable, but stresses that the proportionality assessment depends decisively on the balance between health benefits, costs to industry, and effective implementation and control capacity. In this respect, the Committee points out that not all options provide the same cost-benefit balance.
  
  • • RO1 is considered proportionate but not very incisive, because it entails low costs but also limited health benefits, being very close to the current exposure situation.
    • RO2 is the option that SEAC views most favourably, as it is likely to be proportionate and able to offer a significantly higher level of protection than RO1, with costs that are more closely aligned with the expected benefits.
    • o   RO3 and the option of a very stringent harmonised limit for workers are judged less convincing, especially due to implementation difficulties, higher adaptation costs, and issues related to the availability of sufficiently robust analytical methods and monitoring services. SEAC notes that, particularly with a short transitional period, these options risk not being the most proportionate. This contrasts with the RAC opinion, which instead proposes LV/ELV values attributable to RO3;
      
      
• The Committee believes that the modular design of the proposal gives policymakers useful scope for calibration, allowing them to choose between different combinations of limits and application scenarios. However, SEAC points out that the available documentation does not allow for an unequivocal conclusion on whether a single limit value for all uses or limits differentiated by use category would be preferable.
  
  
• On substitution, SEAC takes a cautious position: the restriction, as designed, does not seem likely to automatically generate broad and immediate substitution, because in practice many companies may primarily react by investing in risk management measures to comply with the limits. The Committee also points out that the information available on alternatives does not allow for a sufficiently robust assessment of the timing and feasibility of substitution.

In summary, SEAC believes that a REACH restriction is an appropriate and proportionate response, but only if it is carefully calibrated. Among the options analysed, RO2 emerges as the most balanced solution, while the most stringent options are considered less proportionate and more challenging in terms of implementation.

Next steps

As with any restriction, following publication of the draft SEAC opinion, interested parties can submit comments within 60 days of its publication. The consultation has already started and will remain open until 17/08/2026. In summary, the consultation aims to collect concrete data on technical feasibility, economic costs, operational impacts and the ability to comply with the proposed limits.

The consultation is available here.

Normachem is available to support companies intending to participate in the consultation.