ADCR Consortium

In December ADCR have 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

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.

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.