As decisions are being published from authorities in EU and in UK (GB), the ADCR Consortium are regularly updating relevant documents.
Today, 1 October, 2024, we provide the following updates:
ADCR Summary of applications submitted in EU and GB table (v September 2024)
This table updates the previous table with Authorisation Numbers (where already available).
ADCR Business Continuity Check Spread Sheet for EU
Spread sheet for EU version September 2024
We expect EU to make decisions for additional ADCR dossiers at the REACH Committee meeting scheduled for 21 to 22 October. Once decisions are known, the ADCR Consortium will update relevant documents again.
The documents made available by ADCR Consortium may be used to help assess business impacts, due to changes in Authorisations. These do not constitute legal guidance and organisations should make their own assessments and consult their own legal experts.
EU update
On Friday 20 September the three first ADCR Authorisation Decisions received a positive vote by the REACH Committee by qualified majority.
The three ADCR dossiers are for three substances; chromium trioxide, sodium dichromate and potassium dichromate, for use in the aerospace and defence industry and its supply chains.
The review periods for all three adopted decision are 12 years from the submission date, and the authorised uses are for chemical conversion coating, passivation of non-aluminium metallic coatings and passivation of stainless steel.
The adopted implementing decisions includes a retroactive measure, aimed at covering the legal gap for uses of potassium dichromate and sodium dichromate for which the uses are authorised as of 22 September 2024.
The final decisions (to our understanding, will be similar to the draft decisions) will be shared in the comitology register as soon as possible, and is expected to still take around four to five weeks.
UK update
On 23 September UK Government published 11 ADCR Authorising Decisions, adopted on 5 September, for dossiers that ADCR submitted under UK REACH Authorisation decisions: UK REACH - GOV.UK (www.gov.uk).
Update 17 September
A post webinar note with questions received and discussed during the webinar is now available.
In addition we have published updated Flow diagram for UK and Spread sheet for UK.
ADCR Applications for Authorisation under both EU and UK REACH
Update 12 September
We apologise for the technical issues during the joining of the webinar.
Please find the slides as presented: ADCR FAQ Webinar 12 September 2024F
and the ADCR FAQ Webinar Recording (mp4 file). The EC presentation is also now available (20 September)
A post webinar note with questions and answers will be published shortly (in next few days)
Date: 12 September 2024
Time: 16:00 - 17:30 PM (CEST)
Location: Online
Are you a downstream user with unanswered questions about ADCR Chromium (VI) Applications for Authorisation under EU and/or UK REACH?
Join us 12 September, 2024, 16:00 CEST for a webinar dedicated to addressing key concerns and queries from downstream users regarding Aerospace and Defence Chromates Reauthorisation Consortium (ADCR) Cr(VI) Applications for Authorisation under EU and UK REACH Regulations. This session will cover questions submitted by downstream users who rely on authorised substances within the aerospace and defence sectors.
Key Speakers:
Who Should Attend?
How to Register:
Registration is simple and free. Secure your place by emailing adcr-info@rpaltd.co.uk with ‘ADCR Webinar’ as the subject, your name and company affiliation.
Do you have questions for discussion at this webinar?
ADCR has published1 a Factual Communication (16 July) and a ADCR FAQ document (16 August) and the European Commission have updated their Q&A ‘REACH and Chromium (VI) substances’ found at https://single-market-economy.ec.europa.eu/sectors/chemicals/reach/authorisation_en
You are also invited to look at the flowcharts and summary of applications found below.
For any queries or questions that are not addressed in the two above ADCR documents, or via the EC Q&A that you would like addressed during the webinar, please email them to adcr-info@rpaltd.co.uk no later than Friday 6 September COB.
Why Attend?
Don’t miss this opportunity to gain clarity and confidence in managing your REACH authorisation and downstream user responsibilities.
Register now to secure your spot. Send an email to adcr-info@rpaltd.co.uk with ‘ADCR Webinar’ as the subject, your name and company affiliation. We will accept registrations until Tuesday 10 September COB.
The ADCR Consortium developed an ADCR FAQ Document answering many questions related to the current applications and supply chain questions.
The ADCR Consortium has updated its News section with a Factual Communication providing concise information on the submitted ADCR dossiers.
Status in EU
On 15 May 2024, ECHA provided draft opinions for authorisation review reports (ARR) and new applications for authorisation (AfA) that were submitted by the Aerospace and Defence Chromates Reauthorisation (ADCR) Consortium in 2022 and 2023.
The recommended authorisation review periods for all the 21 draft opinions are for 12 years. ADCR is currently in the process of reviewing the draft opinions and continues to work with ECHA and the European Commission (EC) for adoption of final decisions on all new AfAs and ARRs before expiry of the existing review period on 21 September 2024.
Regarding the ADCR Authorisation application status related to continued chromate use, the following 3 scenarios apply:
1. ADCR Authorisation review reports
As ADCR submitted the ARRs prior to the latest application date, chromates associated with these ARRs are covered by transitional provisions and may continue to be used under the existing Authorisations originally submitted by ‘Global Chromated Consortium for Aerospace Consortium’ (GCCA) and ‘Chromium VI Compounds for Surface Treatment REACH Authorization Consortium’ (CCST) until a decision is taken by EC on the ARRs.
2. ADCR review reports treated as new applications (associated to CTAC Authorisations)
In April 2023, the European Court of Justice annulled the Authorisation obtained by the Chromium Trioxide Authorisation Consortium (CTAC) for the uses of chromium trioxide (Case C-144/21)( also referred to as the Chemservice decision).
ADCR originally submitted chromium trioxide review reports associated to some of the CTAC Authorisations, however in light of the annulment, these now have the status as new applications for authorisation. Those uses previously authorised under CTAC (REACH/20/18/0-6, REACH/20/18/7-13, and REACH/20/18/14-20) may continue under AfA 0032-01, 0032-02, and 0032-04 until a new decision is taken by the European Commission on these AfAs.
3. ADCR new Applications for Authorisation
Use of chromates under the new AfAs submitted by ADCR cannot begin until decisions are granted by the European Commission.
For all uses applied for by ADCR, there are applications falling into scenario 1 or 2 above. As such there are routes for continued chromate supply for ADCR applied-for uses, from relevant applicant(s), under those scenarios. See the table ‘Summary of applications submitted in EU and GB’ below for information on which ADCR applications are new AfA or ARR.
Status in Great Britain (GB) (UK REACH)
The UK HSE has provided final opinions for all new AfAs and many of the ARRs, where UK HSE also supports 12-year review periods for all opinions. The final opinions for the remaining ARRs are expected by August 2024. It is expected that publication of the authorisation decisions of new AfAs and ARRs will be prior to expiry of the existing review period on 21 September 2024. These applications are summarised in Table 2 in ‘Summary of applications submitted in EU and GB’ below.
Uses covered by ARRs are covered by the transitional measures within Article 61(1) of UK REACH and may continue to be used under the grandfathered Authorisations beyond 21 September 2024 until such a time as a decision is published on the submitted ARRs.
UK-based uses, notified to UK HSE by 1 March 2021 as already taking place under EU-held Authorisations (per UK REACH article 127h) may continue until the relevant EU Authorisation expiry dates. The decision of the EU Court of Justice in Case C-144/21 annulling the Chromium Trioxide Authorisation Consortia (CTACSub) Authorisation has no direct effect in Great Britain.
Support for continuity of ADCR applied-for chromate uses under Authorisation provisions
To support awareness, ADCR has developed flow diagrams and excel spreadsheets that may be used to help assess business impacts, due to changes in Authorisations. These do not constitute legal guidance and organisations should make their own assessments and consult their own legal experts.
Summary of applications submitted in EU and GB (UK REACH)
Flow diagram for EU (download pdf)
Spread sheet for EU (download XL)
Flow diagram for UK update 17 September 2024 (previous Flow diagram for GB (download pdf)
Spread sheet for UK update 17 September 2024 (previous Spread sheet for GB (download XL))
Critical uses of chromates throughout the entire Aerospace and Defence (A&D) industry are at risk – impacting both users of the chromates and chromates-based formulations, as well as the manufacture of parts and components where this involves use of the chromates.
Under the EU REACH Regulation such uses of the chromates requires Authorisation, which is granted by the EU Commission for a specific period of time (the “review period”). It is not possible to continue to use the chromates without an Authorisation.
REACH Authorisations have now been granted to the CTACSub, CCST and GCCA providing 7 years review periods from the Sunset Dates, and all three of these are relevant to A&D uses. The table [available at the link below] provides details of the Authorisation numbers associated with each of the consortium.
Although continued use of these chromates is currently authorised, it will be necessary to re-apply to extend the review period and to ensure the on-going use of the chromates while work progresses to find suitable alternatives.
In February 2023 the Consortium completed the submission of seven review reports (RR) and six new applications for authorisation (AfA) to ECHA. These submissions covered the use of five soluble chromates (chromium trioxide, sodium chromate, sodium dichromate, potassium dichromate and dichromium tris(chromate)) in surface treatment activities in the aerospace and defence (A&D) industry and its supply chains. These supplemented four RR and four AfA previously submitted in November 2022. These include renewals of applications for the original CTACSub, CCST and GCCA consortia. In addition, eight RR and nine AfA have been submitted for review by the UK authorities in accordance with the requirements of the UK REACH Regulation.
Preparation of this first tranche of RRs and AfAs has been supported by over 40 companies across the Aerospace and Defence supply chain, including the largest OEMs in Europe and the UK, as well as importers, formulators and distributors.
The substance/use combinations covered in the first tranche of submissions by the ADCR are shown in the table below. To support the requested review periods, the applications define more clearly each of the substance uses in terms of the actual conditions of use, as well as the associated worker and environmental exposures to the chromates.
| Uses of Cr(VI) substances for (re)authorisation | Chromium trioxide | Sodium dichromate | Potassium dichromate | Sodium chromate | Dichromium tris(chromate) |
|---|---|---|---|---|---|
| Anodising | X | ||||
| Conversion coating | X | X | X | X | |
| Electroplating | X | ||||
| Passivation of (non-Al) metallic coatings | X | X | X | ||
| Passivation of stainless steel | X | X | |||
| Anodise sealing | X | X | X | X | |
| Slurry coatings | X | ||||
| Chromate rinsing after phosphating | X | ||||
| Inorganic finish stripping | X | X | |||
| Pre-treatments | X | X | |||
| Formulation | X | X | X | X | X |
More information on the submissions and the next steps following submission can be found in the following communications:
Work on the second tranche of renewal applications started in 2022 covering substances used in primers and coatings:
For further information concerning the above or the ADCR consortium, please contact email:
The ADCR is now closed to new members with respect to gaining new authorisations covering the use of chromium trioxide (chromic acid), sodium dichromate, potassium dichromate, sodium chromate and dichromium (tris)chromate.