ADCR Consortium

ADCR has developed five Exposure Scenarios (ES) to be placed as annex of the Safety Data Sheet (SDS) for Chromium Trioxide (CT), Dichromium Tris(Chromate) (DtC), Potassium Dichromate (PD), Sodium Chromate (SC) and Sodium Dichromate (SD). The five ES are found in ADCR Guidance and Support

ADCR has today published two recordings, Overview of obligations in EC implementing Decisions for ADCR Authorisations and ADCR - How to execute at a site | Ensure compliance with granted ADCR Authorisations on YouTube. The overview recording, provides information on the granted EC ADCR Authorisations, and walks through the implementing decisions in high level detail and t he second recording, presents two guidance flow charts for ensuring compliance with the required conditions of the ADCR EU REACH Authorisations and the guidance flow chart on feasibility studies. The recordings and flow charts are found in ADCR Guidance and Support . To support the recordings and the guidance flow charts, ADCR invite interested stakeholder to a public Q&A Webinar on 27 March, 2025. More information and how to register .

On Monday 27 January 2025, the European Commission’s implementing decisions for 18 ADCR decisions were published in the Official Journal (as summaries) and made available at the European Commission’s REACH Authorisation website . In connection to this the ADCR Consortium have updated the ADCR Communication ‘ Summary of ADCR applications submitted in EU and GB and decisions status ’ (version 11 February 2025) where all available REACH Authorisation numbers are provided as well as the decision date, the expiry date and link to the implementing decisions, Official Journal summary and the Exposure Scenarios found in the Chemical Safety Report (CSR). All interested parties and downstream users are invited to use the provided information and regularly visit the ADCR website for the latest news and updates. We encourage downstream users, if not already done, to sign up to the ADCR Contact Network to receive the latest information ADCR contact network.

In December ADCR published several updates 5 December Chromates EU Post Decision Webinar Slides, recording and note are published. 10 December Flow Chart Diagram for EU We have updated the Guidance Flow Chart for the ADCR Authorisation Applications with all known REACH Authorisation numbers for EU. The current version is v3 of December 2024 19 December Chromates UK Post Decision Webinar Slides and recording are published

Positive vote on the remaining ADCR dossiers in EU At the REACH Committee meeting 21 to 22 October ( Comitology Register (europa.eu) ) the European Commission and Member States voted to grant authorisation to the remaining 18 ADCR dossiers. The draft decisions the committee voted upon are found on the link above. Note that the authorisations will be valid from the date of their decisions, which will be indicated in the Summary of authorisation decisions to be published in the Official Journal of the EU. In parallel, the full final decisions will be made publicly available and accessible from the Authorisation Decisions List . The publication is expected to take between four to six weeks, and the ADCR Service Team will provide information when the summaries and decisions are published. Updated version of ADCR Summary of applications submitted in EU and GB table (v 21 October) Today, 23 October, 2024, we provide the following updates: ADCR Summary of applications submitted in EU and GB table (v October 2024) This table updates the previous September table with Authorisation Numbers (where already available). ADCR Contact Network Survey The Aerospace and Defence Chromates Re-Authorisation (ADCR) consortium intends to facilitate the exchange of relevant information between authorisation holders and downstream users of the aerospace and defence industry and its supply chains for the use of chromates. With this ADCR Contact Network Survey, the ADCR Service Team aims to identify ADCR downstream users in the European Economic Area (EEA) and Great Britain (GB) in order to establish a contact network. This will enable the ADCR Service Team to contact downstream users directly to provide assistance with the requirements and conditions of the chromate authorisations (e.g. guidance, webinars, templates). Likewise, the contact network will simplify the communication of downstream users with the ADCR consortium. Close cooperation between downstream users and the ADCR consortium will ensure that your site has all required knowledge to be compliant with the ADCR authorisations. The seamless continued use of chromates in the aerospace and defence industry is in the interest of all members of the supply chain. We therefore ask for your support in achieving this goal by participating in the survey and joining the contact network. Please complete this survey – separately for each site operating in the EEA or in GB. The information provided will be used solely for the purposes of supporting imposed obligations of the Authorisation Decisions in EU and UK (GB).

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) .

ADCR has developed a concise document presenting the main aspects of the 21 Dossiers submitted in EU and UK. The Factual Communication summarises the content of the dossiers, and provides information on the Chemical Safety Report, Analysis of Alternatives, research/substitution plans and the Socioeconomic analysis. Key facts are provided in bullet points and the timeline of upcoming authorisation decisions is provided. Authorisations are needed to ensure the continued availability and operation of A&D products in the EEA, since Cr(VI) is still required for manufacture, maintenance, repair and overhaul across the sector. Viable alternatives for every impacted part and process, where Cr(VI) is currently necessary, are not yet available, despite ongoing efforts. ADCR Factual Communication (pdf, 16 July 2024)

The Aerospace and Defence Chromates Reauthorisation (ADCR) Consortium today provided updated information with regard to chromate authorisation provisions in EU and UK (GB). The full information is available on the main page of the ADCR Consortium website ( https://www.adcr-consortium.eu/ ) and includes summary table of authorisations submitted in EU and UK, and supportive flow charts and spreadsheets.

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))

In February 2023 the ADCR 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.

On 20 April 2023, the Court of Justice of the EU issued its judgment in Case C-144/21 European Parliament v European Commission . The case concerned an action brought by the Parliament for the annulment of the Commission's Implementing Decision of 18 December 2020 granting authorisation of certain uses of chromium trioxide (the original CTAC authorisation). As expected, the Court annulled the authorisation decision, but maintained the effects of the decision until the Commission issues a replacement decision. This will very likely be a rejection of the authorisation, as directed by the Court in the present judgment. The judgment followed the Opinion of the Advocate General of 27 October 2022 , and is based on the following factors: Lack of representativeness, reliability and completeness of the submitted worker exposure data, leading to an insufficient risk assessment, based on which the Commission was not in a position to conclude that the socio-economic benefits of the uses in question outweighed their risks to human health. Failure by the Commission to ascertain that there were no suitable alternatives for the uses in question. The Court also considered that the conditions had to be met at the time the decision was adopted. This meant that the Commission could not remedy the lack of sufficient data by providing the obligation for applicants for authorisation to provide additional information in the review reports, such as exposure scenarios and related risk management measures, which were lacking in the risk assessment. However, the Court also stipulated that the effects are to be maintained for only one year from the date of the judgment, which means in practice that the Commission only has until 20 April 2024 to issue its replacement decision. This limit was unexpected; it was not included in the AG's opinion, but has likely been included in order to emphasise the seriousness of the above-described issues with the annulled authorisation, and ensure that these are remedied in future applications, whilst pushing the Commission to take corrective action as soon as possible via the replacement decision.

21 March 2023 The ADCR completed submissions for the five Tranche 1 chromate substances covering 11 uses in February 2023. These are in support of the original submissions made by the parent consortia CTACSub, CCST, and GCCA.

Work has commenced for Tranche 2 substances, and as such a request has been sent to Downstream Users asking for monitoring data for the relevant substances: Strontium chromate Pentazinc chromate octahydroxide Potassium hydroxyoctaoxodizincatedichromate

Update 10/11/2021: The ADCR consortium will be holding a first Telephone Information Session (TIS) with ECHA in November. These sessions aim to give future applicants for authorisation the opportunity to ask case-specific questions regarding the regulatory and procedural aspects of the authorisation application process. Members will be updated through regular communication channels when information becomes available.

Work has now started on collecting information to feed into the socio-economic analysis. Two separate questionnaires have been launched to gather information from suppliers including: Build-to-print suppliers Build-to-design suppliers The questionnaires are available for download, accessible through a unique link which can be requested from ADCR-info@rpaltd.co.uk

Update 10/11/2021: CSR preparation continues, with draft CSRs for all uses to be supported by the consortium being reviewed by the members. Update 15/03/2021: The Aerospace and Defence Chromates Reauthorisation (ADCR) consortium website has been updated, with information and contact details included for downstream users in both the EU and the UK. The first meeting of chemical safety report (CSR) expert group was held on 1 March 2021. The first draft CSR for passivation of stainless steel has been reviewed after comments received at the end of January 2021. The assessment of alternatives (AoA) sub-teams have been set up, with regular meetings taking place. An AoA specific questionnaire is being developed to be circulated to members.

Update 01/07/2020: this extended membership window has now closed. The Aerospace and Defence Chromates Re-Authorisation Consortium (ADCR) announced at the beginning of April that a window for new members to apply was open until the end of May 2020. Unfortunately, this announcement coincided with many companies in the EU being placed in lockdown as a measure to counter the effects of Covid-19. As a result of the lockdown, several potential new applicants have had to delay joining the consortium, particularly where decision makers within businesses, or potential consortium representatives have been temporarily furloughed or placed on reduced hours. The ADCR have therefore decided to extend the membership window until 31st July 2020 . This allowed time for companies to convene the right people within their organisations to provide the necessary support (e.g. technical, legal, or financial advice) for their application. Applications were considered from companies who use chromates within the Aerospace or Defence supply chains. ADCR’s technical support team are available to answer any questions. We will contact all companies and organisations who have registered an interest during the membership window, offering advice and answering questions on the consortium. ADCR Technical Support Team For more information please contact: ADCRInfo@fieldfisher.com

The ADCR is pleased to announce that a webinar was hosted in collaboration with the European Committee for Surface Treatment (CETS) on the 11th of December 2019. This webinar further outlined the value of ADCR membership to A&D sector companies, as well as provide participants the chance to ask questions or clarify any points. If you have any questions regarding this webinar, please contact us at info@adcr-consortium.eu .

A revision to the ADCR consortium cost structure has been agreed by its Steering Committee to provide certainty to SMEs in the Aerospace and Defence (A&D) sector supply chain. The ADCR consortium has been set up to address the continued use of chromates in the Aerospace and Defence sector where substitution is not possible and encompasses the entire A&D supply chain. Although applications will be submitted by upstream stakeholders, dossier preparation costs and application fees will be use-specific and will be shared by paying ADCR members who are end-users and are have an interest in that use. ADCR’s cost sharing arrangements intentionally mean that large companies bear a larger part of the costs than SMEs, as it is recognised that SMEs may not have the financial and/or resource capacity of larger companies. The participation of as many SMEs as possible in ADCR is extremely important. SMEs are vital links in the supply chain and will hold essential information on worker exposure and environmental releases of Cr(VI). SMEs can significantly benefit from their membership of ADCR as they will have the support of their customers in meeting their legal obligations in relation to REACH Authorisation. SMEs have expressed that they would much appreciate certainty from the outset as to the costs of applying for (re-)authorisation of the A&D uses of chromates. In response to this feedback, ADCR can announce that its Steering Committee has decided to review the terms of membership for SMEs and introduce a new cost structure. Its key parameters include: • For SMEs, there will be a modest fixed cost per use applied for . As a result, each SME will be able to estimate its overall authorisation cost by simply knowing how many A&D Cr(VI) uses they wish to support; • For SMEs, no late-joining membership fees will apply . The ADCR Consortium Agreement now reflects the new SME cost structure and all companies that had previously expressed an interest in joining the ADCR and have signed the relevant Memorandum of Understanding have been advised of the new cost structure. Any SME with an interest in joining the ADCR who wishes to get more details about on the new cost structure should contact ADCR-info@rpaltd.co.uk .

In September the ADCR delivered a series of webinars in which the scope of re-Authorisation work was discussed, key principles were explained and next steps were laid out. These webinars were aimed at companies who joined, or are considering joining the ADCR Consortium; but was also available to trade associations who represent potential Consortium members. A recording of this webinar is now available in French, Spanish and German. If you would like to receive access, please send a request to info@adcr-consortium.eu .

Use of chromates in the EU Aerospace and Defence sector All companies in the Aerospace and Defence (A&D) supply chains that use chromates, or specify their use by others, and where those uses are covered by an existing Application for Authorisation are faced with the question: What do we have to do to ensure the continued use of the chromates that are essential to our business? REACH authorisations have a review date, which means that re-authorisation is required if the continued use of the chromates is essential to your company beyond that date. While some companies have been able to substitute away from chromates for some uses, authorisation will continue to be essential for many A&D companies. In the first round of applications for the authorisation of the continued use of chromates, applications were compiled and submitted by upstream suppliers using broad use definitions and most companies in the downstream supply chain could assume that their uses would be covered. Since that time, much has changed and it is now clear that broad definitions of use with very generic use conditions are not acceptable to the authorities. Despite the challenges they face, applications submitted by upstream suppliers are the only option that is possible under the REACH Regulation for covering complex supply chains. However, it is now clear that the active participation of all stakeholders in the supply chain is of critical importance for successfully applying for the re-authorisation of uses for a longer period of time.

Two webinars were held in early November (see dates and time below). The webinars focused on the ADCR, and its activities. In particular, the webinars gave participants the chance to ask any questions they may have had, and to raise any issues that may have been encountered in terms of the chromates authorisations. All Aerospace and Defence stakeholders were welcome to attend on the dates and times below. Dates and times of the webinars: 5 Nov 1600-1700 (CET) 6 Nov 1600-1700 (CET) (Last updated 07/11/2019): This round of webinars has now concluded . If you were unable to attend and would like to view a recording, please contact us at info@adcr-consortium.eu .

Another article on the ADCR was published in Chemical Watch on 10 October 2019. Following the successful launch of the ADCR Consortium in Brussels on 20 September 2019, Chemical Watch reports on the next steps, which are to define the scope of the authorisation applications and to set the first priorities for the work of the Consortium. Initial scoping work is mapping the possible uses in the Aerospace and Defence (A&D) sector of the eight chromates under consideration. This Consortium is unique in that it focuses only on the chromates authorisation requirements for the A&D sector. Steve George, Chair of the ADCR, is quoted as saying: "It may be that the number of specific applications underneath this umbrella of uses goes down significantly ... maybe one of the substances has been substituted by some companies for newer products, while other companies cannot substitute and may need to prepare applications”. During the launch meeting Matti Vainio, ECHA’s head of risk assessment, gave a presentation to the A&D stakeholders. The Chemical Watch article also quotes Mr Vainio as saying that it is positive that stakeholders in the A&D sector are looking to "see what kind of substitution can take place and where they need to prepare authorisation reviews". The ADCR is open to new founding members joining the Consortium, with a deadline of 20 December 2019. For access to the article, see here: https://chemicalwatch.com/83099/aerospace-and-defence-reauthorisation-consortium-identifies-chromates-uses