RAC supports restriction-based approach for chromium(VI), but recommends changes to proposal
ECHA’s Committee for Risk Assessment (RAC) has adopted its opinion on the proposed EU REACH restriction for certain chromium(VI) oxides, oxyacids and salts.
While RAC concluded that a restriction is, in principle, the most appropriate EU-wide measure for managing the identified risks, it did not support the restriction proposal exactly as originally drafted. Instead, RAC recommended a series of conditions and modifications aimed at improving the effectiveness, practicality and monitorability of any future restriction.
For businesses that manufacture, import or use chromium(VI) substances, the opinion provides an important indication of the likely direction of travel. However, significant questions remain regarding exposure limits, emission controls, transition periods and the practical implementation of any future requirements.
Key takeaways for businesses
- RAC supports a restriction-based regulatory approach for certain chromium(VI) substances.
- RAC considers that changes are needed to the restriction proposal before it could become an effective and workable regulatory measure.
- The current SEAC consultation is seeking evidence on proposed exposure limits, emission limits, transition periods and alternatives.
- Businesses still have an opportunity to influence the outcome by providing technical, operational and socio-economic evidence.
- Organisations currently relying on REACH authorisations should begin considering how a future move from authorisation to restriction could affect compliance obligations.
Why this development matters
The proposal is particularly significant because several chromium(VI) substances are currently regulated through the REACH authorisation process.
The European Commission asked ECHA to investigate whether an EU-wide restriction could provide a more effective and harmonised approach to risk management. RAC’s opinion suggests that such a transition remains a realistic possibility, provided the restriction is modified to address concerns around practicality and enforcement.
For industry, the implications extend beyond regulatory compliance. Any future restriction could influence investment decisions, process design, exposure-control measures, emissions management strategies and the continued use of chromium(VI) technologies across a range of industrial sectors.
Who may be affected?
The proposal is potentially relevant to manufacturers, importers and downstream users of chromium(VI) substances, particularly businesses operating in aerospace, defence, automotive, engineering, metal finishing, chemicals, energy and other sectors that rely on chromium(VI)-based processes. The potential impacts will vary depending on the use, existing control measures and the availability of suitable alternatives.
These sectors may wish to review the emerging restriction options carefully, particularly where chromium(VI) substances perform critical technical functions and suitable alternatives remain limited.
Background to the chromium(VI) restriction
ECHA submitted the Annex XV restriction proposal in April 2025 following a request from the European Commission. It concerns certain chromium(VI) oxides, oxyacids and salts and is intended to address risks to human health associated with their use. The Commission had previously expanded ECHA’s mandate so that the restriction work covered at least 12 chromium(VI) substances.
RAC’s assessment considers restriction as an alternative Union-wide risk-management framework on the assumption that the relevant substances would be removed from Annex XIV.
That distinction matters for businesses. Authorisation and restriction impose different regulatory structures. The eventual transition from one system to another, if adopted, could affect how individual uses are controlled and how businesses demonstrate compliance.
Additional background on the proposal, including its scope and the potential treatment of existing authorisations, is available in the European Commission’s Chromium(VI) Restriction Q&A:
What has RAC concluded?
RAC reached two important conclusions.
First, the Committee supports restriction as the regulatory approach in principle for addressing the identified risks at EU level, subject to the assumption concerning removal of the substances from Annex XIV.
Second, RAC did not conclude that the restriction entry originally proposed by ECHA was itself the most appropriate formulation. Its assessment identified issues relating to effectiveness, practicality and monitorability, and the Committee proposed conditions and recommendations intended to improve the eventual restriction entry.
The practical message is therefore more nuanced than either “RAC approved the restriction” or “RAC rejected the proposal”. RAC supports the restriction-based approach but considers changes necessary to the way that approach is implemented.
Which uses are being considered?
The current SEAC consultation groups the affected uses into six categories:
- formulation of mixtures;
- electroplating on plastic substrates;
- electroplating on metal substrates;
- primers and other slurry coatings;
- other surface treatments; and
- uses as functional additives or process aids.
These uses extend across a wide range of industrial supply chains. ECHA’s consultation specifically seeks information from sectors including automotive and transport, aerospace and defence, mechanical engineering, metals, construction, energy, oil and gas, chemical production, plastics, electronics and other industrial activities.
The impact will therefore depend heavily on the specific chromium(VI) use, site conditions, exposure controls, emissions, available alternatives and technical performance requirements.
RAC’s proposed limits are now an important area for evidence
The current SEAC consultation provides further detail on one of the options emerging from RAC’s assessment.
ECHA asks stakeholders to comment on a RAC proposal combining:
- a worker exposure limit of 0.1 µg/m³, which would not be exceeded on any day of the year;
- an air emission limit of 0.25 kg Cr(VI) per year; and
- a water emission limit of 0.15 kg Cr(VI) per year.
The consultation also states that the worker exposure limit would be implemented according to the hierarchy of controls, with respiratory protective equipment used as a temporary measure only where engineering and administrative controls have been exhausted and remain insufficient.
These figures should not be treated as final legal requirements. They are part of the options now being examined within the restriction process.
For some businesses, achieving these levels could require significant investment in engineering controls, emissions-abatement technologies or process changes. This is one reason why ECHA is seeking detailed stakeholder evidence on the feasibility and potential impacts of the proposed restriction options.
The implications of the proposed exposure limits may be particularly significant for organisations currently relying on REACH authorisations. For example, many Member States currently apply the Binding Occupational Exposure Limit (BOEL) of 5 μg/m³. Should significantly lower exposure limits ultimately be adopted under a restriction framework, some operators may face substantial technical and operational challenges in achieving compliance within the currently proposed 18-month transition period.
What is SEAC asking businesses to consider?
SEAC agreed its draft opinion in June 2026, and ECHA opened a 60-day consultation that runs until 17 August 2026. SEAC is expected to consider the consultation evidence before adopting its final opinion later in 2026.
The questions being asked are particularly relevant to businesses because they move beyond the principle of restriction and focus on implementation.
ECHA is seeking evidence on an 18-month proposed transition period, including whether this would provide sufficient time to meet different worker-exposure and emission-control options. It is also asking about worker exposure limits of 1, 0.5 and 0.1 µg/m³, the capacity of suppliers to provide upgraded risk-management equipment, and whether alternative approaches to controlling air emissions could affect decisions to close or relocate operations.
SEAC is also requesting information on the availability and technical and economic feasibility of alternatives, compliance costs, wider impacts, proportionality, enforceability and monitorability.
This makes the present consultation particularly relevant for organisations able to provide site-specific or sector-wide evidence.
What should businesses do now?
Although the final restriction conditions have not yet been determined, organisations using chromium(VI) substances may wish to begin assessing the potential operational, technical and compliance implications.
Key considerations include:
- Current worker exposure levels and monitoring data;
- Existing air and water emissions performance;
- The capability of current engineering controls to meet potential future limits;
- Investment requirements for upgraded equipment or abatement technologies;
- The availability, performance and qualification status of alternatives;
- The time required to implement changes across operations and supply chains.
Organisations that may be significantly affected should also consider participating in the ongoing SEAC consultation. Site-specific evidence relating to costs, technical feasibility, implementation timelines and broader economic impacts may play an important role in shaping the final restriction proposal.
Why evidence matters at this stage
RAC’s opinion establishes an important direction in the risk assessment, but SEAC’s role is to consider the socio-economic aspects of the proposed restriction.
The current consultation specifically asks respondents to support their comments with evidence.
Useful information may therefore include actual monitoring data, investment requirements, operating costs, equipment lead times, production impacts, alternative qualification programmes, supply-chain dependencies, consequences for specific downstream sectors and evidence on the availability of substitutes.
Evidence can also help distinguish situations where compliance may be relatively straightforward from uses or sites where implementation could involve significant technical changes.
What happens next?
SEAC’s consultation closes on 17 August 2026. Its work plan indicates that the Committee expects to review the consultation comments in September and discuss and adopt its final chromium(VI) opinion at its November 2026 meeting.
RAC and SEAC opinions inform the subsequent decision-making process; they do not themselves create a restriction. Any eventual restriction would require a decision to amend REACH Annex XVII through the EU restriction process.
Taken together, RAC’s opinion and the ongoing SEAC consultation indicate that an EU-wide restriction for certain chromium(VI) substances continues to move forward through the REACH process. While the final scope, limits and implementation arrangements remain under consideration, affected organisations may wish to begin assessing potential impacts and consider whether they have evidence that could help inform the final regulatory outcome.
How RPA can help
RPA supports companies and trade associations in assessing and responding to REACH restrictions, including regulatory strategy, analysis of alternatives (AoA), socio-economic analysis (SEA), impact assessment, evidence development and submissions to REACH regulatory processes, including SEAC consultations where relevant.
For the chromium(VI) proposal, this may include assessing the practical implications of different restriction options, evaluating the technical and economic feasibility of alternatives, understanding the implications of potential future compliance requirements, and developing evidence to support regulatory engagement and decision-making.